10/31/2013
Notice of Rule 7026 Showing of Good Faith
Filed by David L Schrader
on behalf of Defendant Casey Marie Anthony
https://drive.google.com/file/d/0B7DjeAMt_BpIekxIR3BoeFJWaG8/edit?usp=sharing
Casey attorney David Schrader files emails showing their good faith efforts to resolve the discovery issues [Depo of Casey], as they stated in Caseys Motion for Protective Order.
In the emails, Caseys attorneys said that
if the Zenaida case is not thrown out after the Hearing on Nov 5th, Caseys attorneys will agree to set a date for the Depo within 30 days of the entry of the Order denying Caseys Motion to Dismiss the Zenaida case.
After Hearing on Oct 17, 2013 regarding the Protective Order for the Depo of Casey, the Judge filed ORDER on Oct 22, 2013
telling Zenaida and Casey attorneys to conduct a Rule 26 Case Management and Discovery Conference on or before October 24, 2013, and confer in good faith to resolve the issues in the Motion for Protective Order and Response.
The judge will rule on the Protective Order for the Depo, AFTER the Hearing on Nov 5, 2013 to rule on Caseys Motion to Dismiss the Zenaida and Kronk cases.
EMAILS regarding the Protective Order for Deposition of Casey
Oct 16, 2013 10:32am
Debra Ferwerda to Shuker
wants to postpone depo until after the Nov 5, 2013 Hearing at 11:00am, to avoid Hearing tomorrow Oct 17th at 11:00am, regarding the Protective Order on the Depo.
If the case is not thrown out after the Nov 5th Hearing, they will discuss the appropriate time and safeguards for a depo.
Oct 16, 2013 11:38am
Scott Shuker to Ferwerda
willing to have Depo after the Nov 5th Hearing but
wants to set a date now for the Depo, and for the Depo to be in Shukers office.
he will discuss safeguards but he wants the date for depo now and the date put in the Order denying Ferwerdas motion [for Protective Order]
if so, Shuker will agree not to seek fees [for his work re: the Motion for Protective Order]
Oct 16, 2013 1:16pm
Debra Ferwerda to Shuker
she cant agree to set a date for Depo now
she does agree to set date for Depo within 30 days of a
final Order on the Motion to Dismiss
Oct 16, 2013 1:36pm
Scott Shuker to Ferwerda
Not a
final Order just invites waiting for an appeal
If Ferwerda will agree to have
date for Depo set within 30 days of entry of an Order Denying Motion to Dismiss, with Depo at Shukers office, and have both aspects put in Order Denying your motion [for Protective Order], Shuker is fine with such
Shuker needs to know by 2:30 so he can arrange to appear at
Hearing tomorrow on Oct 17th, by phone
Oct 17, 2013 7:36am [Day of HEARING at 11:00am on Protective Order]
Debra Ferwerda to Shuker
They outlined their proposed
precautions, for the Depo, on page 6 of their Motion for Protective Order
What is Shukers position?
Oct 17, 2013 8:05am [Day of HEARING at 11:00am on Protective Order]
Scott Shuker to Ferwerda
happy to discuss
precautions, for the Depo, after Ferwerda agrees to Shukers email of yesterday [wants date for Depo set within 30 days after entry of Order Denying Motion to Dismiss, and Depo held at Shukers office and wants these points put in Order Denying Motion for Protective Order].
Shuker wants his fees for travel paid by Casey attorneys because he had to drive over for a Hearing, on Oct 17th [re: Protective Order on Depo], that never should have happened.
10/4/2013
Motion for Protective Order
Filed by David L Schrader
on behalf of Defendant Casey Marie Anthony.
https://docs.google.com/file/d/0B7DjeAMt_BpIVUJHQ3BTaDExY1U/edit?usp=sharing
SAFETY PRECAUTIONS FOR DEPO
Oct 4, 2013 - Casey's attorneys file a MOTION FOR PROTECTIVE ORDER - to stop the deposition set for Oct 9, 2013.
Zenaida has already deposed Casey; and if a deposition is allowed,
Casey should have the same safety precautions that Judge Munyon ordered in State court [depo in disguise and remotely via video - not in person].
The attorneys say that
Casey will again assert her Fifth Amendment rights in any deposition, related to Caylee's death and disappearance.
The attorneys
do not want a video of any deposition made public.
They
do not want the date and time and location of deposition made public even after the deposition is over.
They want
only the parties and their attorneys to attend.
If the transcript of the deposition is filed in the Court file, Casey's attorneys want
2 business days notice so they can file a Motion to SEAL the deposition transcript.
They do not want Casey to have to disclose the names, addresses, dates and parties with whom she has lived since her release from jail in July 2011.
They
want the video of the deposition SEALED, and NEVER disclosed to the public.