about the sticky note on the TES form that Laura's attorney faxed to LDBurdick:
Aug 30, 2010 Status Hearing
LDBurdick asks Judge Perry to put a deadline on turning over evidence, photos
LDB - not in amended Order - docs and tangible evidence - Order is silent for production of those things - as we receive discovery or tangible, been disclosing them - items that I requested - photos, docs in her possession at time of depo, her lawyer faxed to us, ask that Court consider adding deadline for docs and tangible, photos, video depos, stmts already taken of witnesses just listed today.
Baez not decided to use particular witness, becomes a problem, if decision made at last minute.
Judge - also asking that I disclose exhibits? items introduce at trial?
those usually come in at deposition and may offer at trial
LDB - requesting if things like records, photos, stmts, items of tangible evidence that could be using at Hearing or trial, if deadline on the production of those, I could be prepared
(clip)
LDB - things I am concerned about - things
during depo of Laura Buch on Aug 16th - she in NJ - had docs from TES she had a third doc in her possession that LDB did not have, Mason did not have them, her lawyer had to FAX that to us, I determined it was not in TES items - somehow this witness had a doc that was not provided, we did not have, complicated our ability to continue - wait for FAX
Judge - Defense didn't have it?
LDB - it was faxed to me - with sticky/post it note on it that said "From Laura to Mort" - Defense investigator
Laura sent this doc to Mr. Smith - this witness had it
witness had looked at aerial photos and a map - not provided to us either
had to suspend deposition - reschedule Oct 13th [NOTE: depo completed Nov 17, 2010]