Free Republic

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)

You have a good point. It fits with the mind of a psychopath toying with his words. They enjoy those clever twists. He was mingled in a seedy group of people ‘hacking’ and ‘cracking’ real estate, wire transfers, drugs and bad fax dates.

Normally that reference requires adding an “s”. Crackers.

I remember from the around the late 80’s maybe?
Hacker carried a negative connotation. Hackers within their own small groups (IT depts mostly) used to consider themselves crackers. The ones at my work in those days were offended by hacker titles and the destructive goals of delinquents to hack. Cracker, to them was truer to what they considered a fun challenge. Cracking the code or access but nothing hacked in harmful ways like today’s virus creators.

Cracker (without the ‘s’) used by blacks is not a compliment. It is a very derogatory word used for whites by blacks. None of the my black friends think it would be acceptable for a boat in the Bahamas. They said it would be considered offensive, not humorous. A slap in the face to homeland blacks. “The Cracker” is the exact term used by slaves. The white boss that would crack the whip, meaning whip blacks.

We also have the foreign TV series
http://www.imdb.com/title/tt0105977/releaseinfo
“Cracker” (1993)
TV series 1993-1996
An abrasively eccentric forensic psychologist aids in the solving of difficult police cases.

LW reurged the court to reconsider a delay. Judge will allow him to present his arguments via phone but refused the 2nd request for delay.

TMZ has their first response up at Rose’s downloads. 4 pages

Court Docket for Virgie’s case credited to ‘RedCouch and QV’

McCabe’s process server attempted to serve Butterfly four times without success.
http://the-red-couch.blogspot.com/

Georia prosecutor. Sound familiar, Lin Wood home.

As a former prosecutor; she was a corrupt one. Reprminded by higher courts a few times. Her career was headed south until TV make believe came her way. Perper fits right up her alley! They are probably best buds. Victims rights! Even that she rode on a lie. Why people watch and provide ratings for that bully to go on I don’t understand.

The former prosecutor has been reprimanded for unethical conduct by appellate judges at least three times, with one noting:
http://www.talkleft.com/story/2005/05/04/625/41523
“We conclude that the conduct of the prosecuting attorney in this case demonstrated her disregard of the notions of due process and fairness, and was inexcusable,” Chief Justice Robert Benham. Carr v. State, 267 Ga. 701 (1997).

Excellent detail in post 13 here by “Eden”
http://www.tmz.com/2006/10/18/nancy-grace-under-fire/

B

HKS’s motion to delay the June 25th hearing was denied.
Lin Wood had a family vacation planned. The judge said HKS has local counsel and denied the request.

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF TEXAS
HOUSTON DIVISION
HOWARD K. STERN, et at., §
§
Plaintiffs, §
§
versus § MISCELLANEOUS NO. H-07-0680
§
JOHN O’QUINN, et al., §
§
Respondents. §
ORDER
IT IS HEREBY ORDERED that Defendants John O’Quinn and John M. O’Quinn & Associates, PLLC . ‘s Motion to Quash Deposition of Non-Party Wilma Vicedomine (Instrument No.8) is GRANTED until such time as the U.S. District Court in the Southern District of Florida has an opportunity to rule on the motion for protective order. If that Court fails to address the privilege concerns raised in this motion, the Defendants may re-urge them in this proceeding.
The Clerk shall enter this Order and provide a copy to all parties.
SIGNED on this the”of June, 2008, at Houston, Texas.
VANESSA D. GILMORE
UNITED STATES DISTRJCT JUDGE

Gossip
Good Riddance!
June 7th, 2008 fashiongossip
He’s making a big mistake!
Everybody’s favorite famewhoring daddy, Larry Birkhead, is leaving Los Angeles.
more >
http://www.fashion.ie/aggregator/gossip/81152-good-riddance

I have to wonder if LB isn’t slightly retarded or has a serious chem dep problem. His emotional growth is extremely delayed. Here’s another Harvey slow unsuccessful day video that makes you wonder if Harvey isn’t too.
http://www.tmz.com/tmz_main_video?titleid=1591628117

My heart hopes you are right apocalypto. However, we know there are so many shady areas of truth in life and politics and I think after over a year, this is an example.

I suspect Brown was nothing more than a big bag of wind doing a momentary favor. Not one action against a legal killer in over a year. She is free to go on and kill others with that smirk on her face! It wasn’t a difficult case. With what was public information alone was enough for a very damaging case but Brown and the Medical board did nothing with it. Talk is cheap. Bottom line is, they basically look the other way if you have a license to kill.

Celebrity “Sharking” article
(includes hks in the sixth paragraph)
http://www.statesman.com/opinion/content/editorial/stories/06/04/0605cooper_edit.html

And where does one start with the legal Svengali Howard K. Stern? For living the mantra, “no lawsuit left behind”, he should get the award for the lawyer most able to stretch and twist the legal system. The faux baby daddy of Anna Nicole Smith, Stern has engaged in a series of lawsuits purportedly on her behalf. Starting with a dog of a case, the decade long dispute over her deceased husband’s billion dollar estate (which has churned millions in litigation fees for both sides), Stern is a veritable litigation lottery. Even while losing the case at nearly every stage along the way and getting a narrow reprieve from the Supreme Court he has managed to run the score in litigation fees. Along the way he discovered a cornucopia of new suits to file on her behalf. And even after Anna Nicole Smith’s death Stern managed to grab the legal responsibilities of handling her estate and even the financial interests of her young daughter Dannielynn.

Thanks for the notice Liz. I will try and check more often in your absence. You have done so much for all of us, hopefully I can save you a little bit of time in return when you check back on the case.

Best wishes and prayers for a smooth move!

Here’s today’s news :D

5 hours ago, People Mag.
Larry bought a house and is moving Dannielynn to Kentucky and... Selling Anna’s home.
http://www.people.com/people/article/0,,20205087,00.html

(((Re “real judges:” Some of the judges involved in the Anna Nicole-Howie soap opera need to be investigated.)))

Isn’t that the truth!
Sad how courts and the law can be such a joke all too often. Florida has more than their share of nuts and crooks. Texas should be interesting to see how that one goes. Maybe we might get to a PROFESSIONAL judge for the first time in any hks case.

I am tapping my foot to find out more on who was “someone in the government” that Rose said could get inside info. If true, I hope they have an updated resume.

I wasn’t twisting. You said “would have” which indicates not completed. It was a question (see mark ?)

We all form and give opinions on everyone directly in the court docs. I stated my opinion on the depo and doc info and where I stand is all. Many posters will be discussing them and as you are a participant, discuss you.

I just want to be clear. It isn’t ‘personalizing’ as if you were only a poster. You are IN the case and by that, will indeed be discussed by posters the same as hks, larry, Rita etc are discussed. You are a participant yet chose to be a poster too. That is unusual but I don’t think posters should be attacked because of your unusual choice. I shall carry on as I always have, discussing the case and the participants. Most participants in cases aren’t usually active on message boards. Well, better categorize that, not openly anyway. For all we know, hks, Bonnie, LarrySue, Rita etc could sign up as Goldilocks and the three bears lol.

Not sure why you would direct me to McCabe. I didn’t question anything he has done. He is a busy man and I have no desire to bother him with message board nonsense. I don’t see him as a prop to be used for snide remarks either. I give the man more respect than that. Poor McCabe, I can see 10,000 nonsense emails. HI, QV told me to contact you. If he isn’t a drinking man he might become one.

I am sure there is a ton more to come out! I have never seen an attorney that would tip their whole hand early on. And, most hold a few surprises. Those should be fun. lol Thank goodness I am in the gallery - all we do is sit back, wait, watch and enjoy the show as it unfolds. Way too early to predict anything though. It might never even make it to a trial. I remember the Ramsey cases, all that hype and arguing, press and interviews. Never was a trial. They settled behind closed doors and were yesterday’s news.

Speaking of computer forensics ...
The scary part if it comes to that can be — a lot depends on which expert and which software is used. I have seen some lousy work produced in courts and have seen so called ‘experts’ that weren’t even familiar with the correct terminology. Maybe we should start a lottery though on where hks says his hard drive went. :D

A. It died!
B. Anna wanted me to get rid of it
C. Moe took it and won’t give it back

Whew!
I know there are spoofs but that wasn’t the site I was familiar with. I went back and read their “About” and that explained it all. They give a site start date as 300 BC or something like that. lol

Probably it to be similiar for him. Her book came out in Sept 2007. After reviewing that date, it would put us no where near a deadline. This case isn’t as old as it feels in my mind lol.

If the judge were to toss out hks’ because Rita is ‘severely prejudiced’ to defend herself, then I don’t see LB able to do anything either.

jiminy Christmas I am out of the loop. May 7th date. Is this true? What in the world???????
http://www.datelinehollywood.com/dateline_hollywood/2008/05/howard-k-stern.html

I am not a part of this case. Your personal attack is something Jim has requested not be done.

In any regard, I didn’t make howard or QV or anyone else a part of this case but they are right there in all the court docs. I don’t see how having an opinion on ANY deposition, filing or party in those legal docs (linked here) is going “Outside” of the case.

LOL. Dim bulb, we agree.
What about his threats to sue for slander? Any idea what his time limit is to file? Or if it has passed?

“Would have..” ????
Are you saying you didn’t / won’t hand over everything you have ????

You know QV, you are on a soap box in my eyes and your repeated woe is me tune is old to me. What howard’s side writes about you?! I haven’t read or heard one thing about you. You still living on their boards maybe? I see nothing about you in the national press / media. I don’t see cameras following your every move, picking you apart, making fun of you. I don’t see Harvey making up stuff about your personal past or claiming you were an incest perp or ET slamming you every night.

I call it as I see it. Not everyone’s style but then we aren’t all clones are we. Do you prefer backstabbing? Dishonesty? It isn’t like I post thinking it won’t be read. Or that I write to get praises. Appears to me you expect everyone to say how great you are for trying to pull the body out of the building you set fire to. I see it as you set the fire, the least you could do is toss a small bucket of water out. You can play the turn this on me all you want if that is what helps you sleep. Bad me, I don’t have damaging a mom on my conscience.

From my chair, it has nothing to do with my forgiveness. I wasn’t the mom you burned at the stake. Thank God, I have never lost a daughter and grandson in such a horrific way much less had to endure a very public tar and feathering for no reason at all while losing my burial rights to the likes of hks who you didn’t even know! I state opinions on one little board in a small corner of a big world. I don’t know OJ either but have opinions about him. I don’t know Hillary and have a few there too.

Do you think Virgie didn’t cry over what you were doing to her? I saw many say they cried for Virgie. Often because of your nasty deeds against her. You made a concerted effort day and night to crucify her. I can only imagine her pain and fears through all that. But giving my opinion here of actual events or court papers, not made up lies isn’t a conspiracy or national campaign to ruin a life.

You are right, I don’t know you. I saw and read what you are capable of doing though. You KNEW she was not involved in those deaths. But you didn’t care about that or what you were doing to her. If some can pass over all that easily, good for them. I never claimed to be one of them though.

From my way of thinking it is like an abusive husband that beats his wife bloody then says oh, sorry, and offers to take her to dinner - all forgotten, bring out the band and shake the man’s hand. I don’t feel like shaking hands with him and make no apologies for that decision. I could care less if someone else chooses to shake that hand. Never been a groupie so it should come as no surprise I still am not. I didn’t follow like sheep on the poor howard wagon either.

Are you saying O’Quinn only filed against howie after you contacted him? Wow, another scoop for you. McCabe, O’Quinn and team are just door stops in your hall of fame and we heard it hear first.

I just tried going to Mr.Controversy.
Looks like he might have skipped on the bill too lol
http://www.mrcontroversy.com/
What you get is redirected to-—
http://host.bahamashost.com/suspended.page/
This Account Has Been Suspended
Please contact the billing/support department as soon as possible.

We knew he was low life, not surprised he had to skip town. Normal behavior - Rats scurry when you turn the lights on.

If I understand you correctly then it sounds like hks’s case could end up tossed out even. If the Judge said ‘severly prejudice THE CASE’. Wow. IIRC, the American way .. I think the whole case gets tossed. Could be what hks planned all along when he had them ‘disappear’ with the nannies. The chaos served his intended function and he no longer needs Lincoln, the nannies or even that case. The inquest was successful for him. I could be way off, just my guess trying to think like a psyhco.

Exhibit B -
Rose should change her site to “Begging for dollars.com”
OMG, First Amendment!? WTH, is she really that dumb? The LAW clearly separates freedom of speech from MALICE and DEFAMATION (her plotted evil doings). “ALL Bloggers” “in it for the long haul.” OMG, that was a winner. What a con job and a bad one at that. Like HER law suit is going to stop all until the end of time and open the flood gates for anyone to systematicaly go after anyone, anytime, with any lie. What a ditz!

McCabe’s opposition response -
Those docs you linked had be roaring. I had tears I was laughing so hard at some of it.
Attorney went to the wrong court house. ROFL
“the Turners seem oblivious to rules” HARDYHARHARROFLMAO
“disingenuous” LMAO!
I love that McCabe. :D

Pitiful to see the truth in other places. QV was so hungry for her own need for some odd ball bloggers fame of ‘heard it here first’ it is sickening. We now know it was her that just couldn’t wait to happily devour an innocent human being like a wild beast and it turns out she didn’t give a damn about the truth! Wow! And she has the nerve to grumble about being harassed?! GMAB. She first handly relished in putting all her hate out then whines when a tiny drop falls in her lap?!

The sadiest of all to me is - they have learned nothing from what I read. I see her and Havana still more involved in the inner cat fight with no sense of what they did to an innocent mom / Grandmother at the worst time in life losing her loved ones. Did you notice they had to be TOLD to keep it formal? Like there is some joke here?

All in all, I find Havana less guarded though. I don’t see that with QV. QV is still avoiding and dancing around a lot in many ways. She comes across to me as covering her own ass not as any real search for truth. Finding out she was the origin of the incest lies fits right in with what I see in her words even now. They both sound like they rehearsed their words well between themselves. We all know they were out to get Virgie any way they could. “Too help hks” .. trying to pad it BS. How often do two people use the same words and phrases unless they rehearsed. It was far more than helping hks and we all know it. They became obsessed with hate for Virgie. They know very well they were working 24/7 to slit Virgie’s throat any turn they could. Neither spoke the real truth; that whole group was obsessed with hate & spewing lies & their venom that went way beyond helping anyone. It was pure selfish dark evil at work. I don’t see them as anything more than co-operating to avoid their own 85,000.00 legal bills.

Hi apocalypto,

Hum, not sure why it wouldn’t work but then; I have never searched by thread title. I’ve always put in a name to get to the thread if I didn’t have a new comment link when logging in. Of course it was easier way back when I followed more often. Lizard’s is the best name to use nowadays. She is terrific about updating us.

I try to read the docs Liz is so kind to provide but that is about all I do follow on this anymore. I haven’t followed much of anything in a long time. I’ve always felt that HKS’s ‘luck’ has to run out one day though, it is just a matter of when. This life or the next, he has a big price to pay one way or another. I admit to feeling a bit of glee in that we may get to see a teeny tiny part of one lashing for him. I think the wonderful Mr John O’Quinn / Neil team might have ol killer in a corner finally and we get to watch. :D Not prison for homicide but I enjoy what whatever crumbs JO’Q can toss out.

Is anything going on in Rita’s case lately? Or anything coming up? I did a google but didn’t find anything. That case seems awful quiet.

As for Buckhead” here’s a blurb that is funny.
http://www.fashion.ie/aggregator/gossip/75885-dannielynn-all-grown-still-pimped-out
He is so phony! That constant kissing for photo ops is sickening. He is too stupid to know that a normal parent simply doesn’t force it like he invariably does. He gives himself away on that alone. No wonder he was on the other side of the camera, he isn’t very good on this side if you ask me. He always looks like a homeless bum that needs a bath to me.
Or this quote
http://www.metro.co.uk/fame/article.html?in_article_id=148362&in_page_id=7&in_a_source=

If she is too young for the cartoon, how the H does she know the characters?! Duh, snitched on himself again. What a fool. That poor kid doesn’t stand a chance. Pray for miracles.

thanks Lizarde! You are always dependable to update here and I appreciate it.

It was everything that was suspected going on behind the scenes with the evil ones. They even busted Howard in the Bahamas acting as Bonnie online. You have to really love that one :D All their sneaking around and tracking people then they bust the very one they claim to want to help. Hysterical. And I believe that part will be difficult for HKS to explain. That is IF the turncoats decide to be honest and provide the IP’s as well if they haven’t already. I bet there is a lot more to come. Should be interesting to follow.

What they did to Virgie was pure evil that can never be undone no matter how many turncoats decide they can’t pay a lawyer and ran to save themselves the only way they might.
I don’t buy into they developed a conscience and suddenly wanted to help Virgie. Any decent human being would never have been so disgustingly cruel in the first place. I think QV and Havana made a calculated move to save their own butts. Smart move! Actually, their only move unless they are rich and can fork over tons of lawyer fees when name in the suit with the others.

Rose is whining she can’t find a lawyer. OMG lmao! Wasn’t she pretending to be some big legal eagle of sorts? ROFL. Isn’t Krista jumping out of her seat to help? Did Lin Wood toss his elves to the lions? Hum, sweet justice doesn’t always occur in a court room does it. I am hoping this will be a great lesson to many posters that take things to far. (at Rose’s deserved expense of course)

I am not naive as a rule, but when posters become as cruel and vindictive as the criminals we discuss it is mind boggling!

On a lighter note-
O’Quinns team are comedians often. They have a sense of humor I enjoy. Their depos always have something that cracks me up.

Thanks again for all your help!