THIS is straight from the complaint, and is
EXACTLY what they are alleging happened:
10. On or around the morning of July 13, 2011, Defendants ADAM, DINA
and NINA, and each of them, conspired to plan, and did in fact, enter into a
common scheme of conduct with the intent to murder REBECCA in Coronado, California,
and did in fact, murder REBECCA by each of them personally
committing one or more of the following acts in furtherance of the common scheme
and conspiracy:
(a) striking REBECCA on the head multiple times with a blunt instrument;
(b) physically restraining her;
(c) further restraining her by binding her legs with tape;
(d) gagging her;
(e) binding her hands behind her back with rope;
(f) binding her ankles together with rope;
(g) removing the previously placed tape from her legs;
(h) strangling her to the point of unconsciousness or death;
(i) making and placing a rope noose around her neck;
(j) tying the other end of the rope leading to the noose to a bed;
(k) carrying her to the adjacent balcony and pushing her over the railing of
the balcony causing her to fall and, if she was still alive at that time, to then
die by asphyxiation.
(l) during the course of the conspiracy to murder REBECCA, each of the
Defendants also kept watch to avoid detection and removed evidence of the
acts which they committed, including wiping down objects they had touched
in order to remove DNA and finger prints; and
(m) as a further ploy to cover up their wrongdoing, and in furtherance of their
common scheme, Defendants painted the following words on the inside of
door near the balcony where she was left hanging:
SHE SAVED HIM CAN YOU SAVE HER
11. On the morning of July 13, 2011, REBECCA was found dead, naked,
bound and gagged, with a rope noose around her neck. Her cause of death was
asphyxiation, which was caused by either manual strangulation before she was
hanged, or from being hanged with a rope noose around her neck from the second
story deck of the Coronado vacation home at which she was staying. The Coroner
for the County of San Diego determined that she died on that date.
12. 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. Because the only individuals who know the true facts and
sequence of events with absolute certainty are the decedent REBECCA and the
Defendants themselves, the allegations made herein are made on information and
belief based on the evidence that has been uncovered to date. Plaintiffs intend to
seek leave to amend the Complaint as additional facts are developed and uncovered
during the course of discovery.
13. Due to DINA’s prior incidents of confronting and threatening
DECEDENT, DINA’s prior history of being unable to control her anger, her
1040 Ocean Boulevard residence the evening of the murder, that on the evening of
July 12, 2011, DINA aggressively confronted the DECEDENT at the Ocean
Boulevard residence, along with her sister, NINA. This confrontation arose from an
accident the prior day when DINA’s son 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 babysitting Maxfield at the time of the fall.
14. Plaintiffs allege, based in part on the mud found on DECEDENT’s feet
and four subgaleal hemorrhages on the back right side of her head, that in response
to the aggressive confrontation from Defendants DINA and NINA, DECEDENT,
fearing for her safety, attempted to flee the residence. However, before DECEDENT
could evade her attackers, she was struck four times on the back of the head with a
blunt object by DINA, rendering her unconscious. Plaintiffs believe that at this time,
ADAM, who had taken an Ambien earlier in the evening and was sleeping in the
guest house at the residence, was awakened by the commotion and came to the
scene.
15. Once confronted with the reality that DECEDENT would eventually
regain consciousness, and thereafter probably disclose information about this
incident and possibly other information of a personal nature that could cause public
humiliation and embarrassment to Defendants and Jonah Shacknai (i.e., the ex-
husband of DINA, father of Maxfield, brother of ADAM and the boyfriend of the
DECEDENT), the Defendants entered in to a conspiracy and common scheme to
murder the DECEDENT and hide their involvement.
16. Due to the lack of markings on her body evidencing her being dragged
back into the house, Plaintiffs allege that ADAM carried the DECEDENT back into
the house. Based on the facts that DECEDENT was found naked and the clothing
she was wearing on that date was not found at the scene of the murder, Plaintiffs
allege that once inside the residence, the Defendants stripped off her clothing. Based
on the tape residue found on DECEDENT’s legs, and the fact that no tape with
similar adhesive was found at the scene, Plaintiffs allege that the Defendants first
restrained 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.
17. Thereafter, the Defendants contrived an elaborate scheme to murder
REBECCA and conceal their involvement. DINA previously resided in the
residence, and thus was familiar with where to find items necessary to further the
scheme, including, inter alia, the ski rope used to bind and hang the DECEDENT.
18. The final scheme agreed to that evening by the Defendants involved
binding DECEDENT’s hands (behind her back) and ankles with rope they found at
the residence. Plaintiffs allege that based on the knots having nautical qualities and
ADAM being a tug boat captain with experience tying nautical knots, that ADAM
bound the DECEDENT. Plaintiffs further base this allegation on the fact that the
ropes had the same black paint residue found on DECEDENT’s nipples, thus
implicating the person who tied the knots as the person who also pinched the
Decedent’s nipples, and that ADAM had admitted to masturbating to










on his cell phone that evening, the further inference being that the two instances of
sexual behavior are consistent with ADAM’s state of mind that evening. The
Defendants also placed a blue t-shirt around her neck and stuffed it in her mouth,
using it as a gag to both muffle her screams and cover up any marks that would
suggest murder. Based on the type of injury to DECEDENT’s throat, which
commonly occurs with strangulation and is unlikely to occur with a hanging, and
the amount of strength needed to create such injury, Plaintiffs allege that in the early
hours of July 13, 2011, ADAM choked REBECCA to death.
19. Once they murdered REBECCA, DINA instructed ADAM to leave a
message was painted using black paint at a height that is consistent with an
individual who is approximately the height of ADAM. The message read: “SHE
SAVED HIM. CAN YOU SAVE HER.”
20. ADAM, based on black paint residue found on the noose, then
tightened the noose around the neck of the DECEDENT and attached the rope to the
base of the bed. ADAM then picked up REBECCA, then threw her over the edge of
the adjacent balcony. Either DINA or NINA was sitting on the bed to which the
rope was secured, to ensure that the bed remained anchored to the floor as
evidenced by the bed having moved less than a foot. While the scheme was being
perpetrated, Defendants DINA and NINA also acted as look outs to avoid detection
and encouraged ADAM to commit the acts alleged herein. Although each of the
Defendants was in part responsible for putting the DECEDENT in harms way, none
of them made any effort to help her or to save her from the injuries that eventually
resulted in her death.
21. The Defendants were careful to remove any evidence of their
involvement, including the disposal of the tape and REBECCA’s clothes. Once the
staging was complete, the Defendants fled the scene, instructing ADAM to call the
police in the early morning with claims of suicide.
Each of the defendants had his/her own motives for committing these
wrongful acts, including anger and revenge against REBECCA arising from the
fatal injuries suffered by six-year-old Maxwell 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. The Defendants were further motivated to silence
REBECCA in order to keep her from disclosing matters that could prove extremely
embarrassing to the Defendants and their families.
As the Zahau.'s lawyer recently said, "As a lawyer what you really like to see are statements by the opposition that are so outrageous that they are easily disproved and thats exactly the way it is in this case."
Link please? The entire document is available earlier in the thread.