15. Have you ever told your mother that Neil (Rebecca's ex-husband) tried to strangle Rebecca?
17. Do you still believe that Jonah should have protected Rebecca?
18. What evidence do you have as a plaintiff that you believe prove that my client killed Rebecca?
23. Are you aware of anybody who saw my client hit Rebecca on the night or morning of her death?
24. Okay. So you -- is it correct that you decided to file this lawsuit solely based upon those opinions (i.e. that her sister would not commit suicide given that Max was doing better, she had to stay strong for Jonah and she would see her Dad in a couple of months)?
25. As you sit here today, are you aware of any witnesses who will testify that any of the defendants were present with Rebecca at the house after midnight on the morning that she was found?
26. Do you have any evidence or know of any witnesses who place any of the three defendants at the house within six hours of Rebecca's death?
28. So the complaint alleges that my client struck Rebecca multiple times on her head with a blunt instrument, correct? What evidence do you have to support that allegation?
29. You also allege that my client physically restrained Rebecca, true? What evidence do you have to support that allegation?
30. The complaint alleges that my client gagged Rebecca. What evidence do you have to support that allegation?
31. The complaint claims that my client assisted in binding Rebecca's hands behind her back with a rope. What evidence do you have to support that allegation?
33. On page 6, line 18, it says that each of the defendants named herein were present at the location where the murder of Rebecca occurred and all of them actively participated in the planning, implementation, execution, and subsequent concealment of the scheme to murder Rebecca. What evidence do you have to support that allegation?
34. On page 7 of your first amendment 14 complaint, it states that on the evening of July 12, 2011, Dina aggressively confronted the decedent at the Ocean Boulevard residence. What evidence do you have to support that allegation?
35. ?
36. You state in your first amended complaint, page 7, line 9, that on the evening of July 12, 2011, Dina aggressively confronted the decedent at the Ocean Boulevard residence along with her sister Nina. What evidence do you have to support that allegation?
37. You also state in your compliant on page 7, line 18, that Rebecca attempted to flee the residence. What evidence, if any, do you have to support that allegation?
38. On page 8, around line 4, you claim that Adam carried the decedent back into the house. What facts do you have to base that allegation on?
39. Same page, around line 7, you claim that the defendants stripped off her clothing. What evidence do you have to base that allegation on?
40. Same page, line 9, etc., you claim that the defendants first restrained the decedent with tape and gagged her while they were devising and planning the rest of the scheme and later removed the tape from the scene. What evidence do you have to base that allegation on?
41. Page 8, line 16, etc., you claim that the final scheme agreed to that evening by the defendants involved binding decedent's hands behind her back and ankles with a rope they found at the residence. What evidence do you have upon which you base that allegation?
42. In your complaint, you claim on page 9, line 12, that either Dina or Nina was sitting on the bed to which the rope was secured. What evidence do you have to support that allegation?
43. Page 9, line 20, etc., you claim that the defendants were careful to remove any evidence of their involvement, including the disposal of the tape and Rebecca's clothes. What evidence do you have to support that allegation?
46. What evidence do you have from the autopsy report that the that any of the defendants struck Rebecca on the head multiple times with a blunt instrument?
47. ?
48. The next highlighted portion is same page, line 12 to 14. I'll read it. It says, "Maxfield fell over a second-floor railing at the Ocean Boulevard residence causing him brain damage and eventually his death on July 16, 2011. Decedent was baby-sitting Maxfield at the time of the fall." I'll ask the broader question first: What evidence, if any, do you have to support that allegation?
49. So this is what was highlighted: "Each of the defendants had his or her own motives for committing these wrongful acts, including anger and revenge against Rebecca arising from the fatal injuries suffered by a six-year-old Maxfield Shacknai -- nephew to Adam, niece to Nina, and daughter to Dina -- while Rebecca was taking care of him two days before she was murdered. In addition, defendant Dina Shacknai was extremely jealous of Rebecca's relationship with her ex-husband Jonah Shacknai and her now deceased son Maxwell (sic)." So what evidence, if any, do you have to support these allegations?
50. So your counsel has now highlighted page 14, line 14 and 15. They state: "Immediately prior to her murder, Rebecca owned the clothing she was wearing and also owned and possessed other personal property." What -- first of all, what's your basis for stating this?
51. So because you don't have the clothes, you believe that somebody threw them out? And because you don't have the clothes, you believe that that somebody is one of the three
defendants?
52. And then you say in this that she also owned and possessed other personal property. What do you mean by "owned and possessed other property"? What specifically are you referring to in this statement?
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