K_Z
Verified Anesthetist
- Joined
- Nov 8, 2010
- Messages
- 6,657
- Reaction score
- 2,497
The 16 areas identified by DS attorneys that lead to the 68 instances of counsel advising MZL not to answer (BBM):
https://roa.sdcourt.ca.gov/roa/face..._Motion_to_Compel_Discovery_1427504398857.pdf
(I think they left out a few critical areas. Like MZL's shoe size, what brand of toothpaste she uses, and whether she prefers margarine or butter, and why.)
Here, Defendant's line of questioning at Ms. Zahau- Loehner's deposition falls into 16 broad categories:
-Issues where Attorney-client Privilege asserted as an Objection.
i. The identity of the family member controlling the case and exposure with media. (See,
Separate Statement issue nos. 2, 3, 4)
ii. Knowledge of Rebecca's actions and records (See, Separate Statement issue nos. 5, 10)
iii. Information Ms. Zahau-Loehner has reviewed before making statements to the media
(See, Separate Statement issue nos. 11)
iv. The investigation into Rebecca's death (See, Separate Statement issue nos. 12, 13, 14)
v. Information about Jonah and the decision not to sue him for wrongful death Separate Statement issue nos. 16, 17, 65, 67)
vi, The evidence to support case against defendants and the allegations asserted in the
Complaint (See, Separate Statement issue nos. 18, 22, 23, 24, 25, 26, 28-43, 46-52)
vii. Max's health and death (See, Separate Statement issue nos. 19, 20, 21, 66, 68)
viii. Information supporting responses to written discovery (See, Separate Statement issue
nos. 54-61)(Attorney work product protection also asserted at issue no 56)
ix. Information about defendant from sources other than Rebecca
-Issues where Marital Spousal Privilege asserted as an Objection.
x. Husband's investigation of Rebecca's death (See, Separate Statement issue nos. 27)
xi. Rebecca's cell phone (See, Separate Statement issue nos. 44-45)
xii. Her confrontations with her husband(See, Separate Statement issue nos. 62-63)
-Issues where Right to Privacy asserted s an Objection
xiii. Her brother's pictures on Facebook (See, Separate Statement issue nos. 1)
xiv. Xena's guardianship and relationship with her mother (See, Separate Statement issue
nos. 7, 8,9)
xv. Investigators meetings with witnesses (See, Separate Statement issue nos. 14)
xvi. Rebecca's personal relationships (See, Separate Statement issue nos. 15)
https://roa.sdcourt.ca.gov/roa/face..._Motion_to_Compel_Discovery_1427504398857.pdf
(I think they left out a few critical areas. Like MZL's shoe size, what brand of toothpaste she uses, and whether she prefers margarine or butter, and why.)