Max Shacknai Rebecca Zahau Forum

A place to discuss the Max Shacknai and Rebecca Zahau cases
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 Post subject: AS Wants Answers from Zahaus + Greer, + $23,500 in Sanctions
PostPosted: Tue Feb 28, 2017 7:10 pm 
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From ROA 555, the 400+ page document from Adam's Lawyers, we learn that

Jonah Shacknai paid for all of Rebecca Zahau's funeral and burial costs (Pari admits this).

Adam Shacknai is seeking all information between Ann Rule and the Zahaus or Anne Bremer (and posse member Kathleen McKenna, who worked with the Ann/Annes on the book?),

AS wants names of witnesses mentioned in Zahau letters to the California AG.

Mary Zahau Loehner may not have been the legal representative of the "estate" when the civil suit was filed.

It is possible that Mary Zahau Loehner has been convicted of a felony, since she refused to provide an answer to that question. If she has not been convicted of a felony, why wouldn't she say so?

From ROA 555:


The hearing for this Motion is scheduled for March 10.


- By law, Interrogatories Parties are required "to state the truth, the whole truth, and nothing but the truth in answering written interrogatories...

- Adam's Motion is seekng the Facts, documents, and physical evidence behind the Zahaus' (fabricated) Second Amended Complaint.

- Wants identity of witnesses and "so-called confidential informant" mentioned in letter to attorney general in 2012.

- Mary Zahau-Loehner's status as representative or executor of the Estate of Rebecca Zahau or the Estate of Robert Zahau is in question.

- Regarding the petition the Zahaus sent to the California Attorney General, Mr. Shacknai seeks an executed copy, in part, because individuals who signed the petition could be selected as potential jurors.

- A party may request that any other party "admit the truth of specified matters of fact, opinion relating to fact, or application of law to fact" relevant to the subject matter of the action that is not privileged or subject to some other valid protection.

A Sample of some of the admissions that AS is seeking:

REQUESTS FOR ADMISSIONS TO ESTATE OF ROBERT ZAHAU

Admit that you have no personal knowledge that Adam Shacknai converted any possessions belonging to the DECEDENT.

Admit that YOU have no personal information regarding any allegation in the Second Amended Complaint.

Admit that the San Diego Sheriff's Department determined that the DECEDENT'S death was Admit that the San Diego Medical Examiner determined that the DECEDENT'S death was a suicide.

For the Court's reference, the outstanding RFAs at issue that were served with this Form Interrogatory include the following:

RFA 21: Admit that YOU have no personal knowledge that Adam Shacknai converted any possessions belonging to the DECEDENT.

RFA 22: Admit that YOU have no personal information regarding any allegation in the Second Amended Complaint.

RFA 23: Admit that the San Diego Sheriff's Department determined that the DECEDENT's death was a suicide.

RFA 24: Admit that the San Diego Medical Examiner determined that the DECEDENT's death was a suicide.

RFA 25: Admit that YOU have not suffered any damages as a result of the DECEDENT's death.

RFA 26: Admit that YOU have no assets.

RFA 27: Admit that the DECEDENT did not support Robert Zahau financially.

RFA 28: Admit that the DECEDENT did not provide household services for Robert Zahau.

Admit that one or more of the pages of the copy of the police report YOU received from the Coronado Police Department included a stamp that set forth "NOT FOR THIRD PARTY RELEASE."

These requests are focused on whether Plaintiff has provided a copy of the police report that was stamped "NOT FOR THIRD PARTY RELEASE" to a third party. Plaintiffs have put their credibility at issue in bringing these claims; this goes to Plaintiffs' credibility, to the issue of potential discovery sanctions, and also to the identity of potential third party witnesses at trial.

Documents produced from Simon & Schuster in response to a subpoena reveal 1) that Plaintiffs were in direct contact with author Ann Rule 2) that Plaintiff's prior counsel had offered to provide the complete police file, and 3) that author Ann Rule had reviewed the police reports. Mr. Shacknai is entitled to a verified further response from Plaintiffs confirming whether any Plaintiff (or anyone acting on any Plaintiff's behalf) provided this report to Ms. Rule despite the prohibition against doing so. Given that Plaintiffs only response to these requests has been meritless objections, the Court should order that Plaintiff immediately provide further substantive responses.

Some of the admissions and interrogatories they reused to answer:

REQUESTS FOR ADMISSION TO ESTATE OF REBECCA ZAHAU (SET ONE)

REQUEST FOR ADMISSION NO. 21

Admit that you have no personal knowledge that Adam Shacknai converted any possessions belonging to the DECEDENT.

REQUEST FOR ADMISSION NO. 22

Admit that YOU have no personal information regarding any allegation in the Second Amended Complaint.

REQUEST FOR ADMISSION NO. 22

Admit that YOU have no personal information regarding any allegation in the Second Amended Complaint.

REQUEST FOR ADMISSION NO. 23

Admit that the San Diego Sheriffs Department determined that the DECEDENT'S death was a suicide.

REQUEST FOR ADMISSION NO. 24

Admit that the San Diego Medical Examiner determined that the DECEDENT'S death was a Alleged Law Enforcement Failures (Nos. 70-76)

These interrogatories are focused on specific contentions by Plaintiff of alleged failures by law enforcement related to its investigation into the death of the decedent.

REQUEST FOR PRODUCTION NO. 64

All DOCUMENTS that support YOUR contention that "investigative leads ... may not have been properly pursued by law enforcement," as alleged in Plaintiffs' Memorandum of Pointi and AUthorities in Opposition to Adam Shacknai's Motion for Early Designation of Experts (the , "Opposition") at 3:3-4.

REQUEST FOR PRODUCTION NO. 65

All DOCUMENTS relating to the circumstantial evidence that is or was necessary to gather that was not collected by the police as alleged in the Opposition: "it is necessary to gather DECEDENT] circumstantial evidence from third parties, including some identified in the voluminous police investigative files and some [of] which may not have been collected by the police ...." Opp. at 2 n.2.

REQUEST FOR PRODUCTION NO. 66

MI DOCUMENTS that support YOUR contention that law enforcement may not have
collected "circumstantial evidence," as alleged in the Opposition: "it is necessary to gather circumstantial evidence from third parties, including some identified in the voluminous police investigative files and some [of] which may not have been collected by the police ...." Opp. at 2 11.2.

REQUEST FOR PRODUCTION NO. 67

All DOCUMENTS reflecting, concerning, or consisting of evidence available to Plaintiffs that has not come from the law enforcement investigative materials, as described in the Opposition: "to date the documentary evidence available to Plaintiffs has come primarily froin the law enforcement investigative materials ...." Opp. at 2:23-3:1.

REQUEST FOR PRODUCTION NO. 68

MI DOCUMENTS reflecting, concerning, or consisting of communications between any member of the Zahau family, on the one hand, and the CORONADO POLICE DEPARTMENT, on the other hand.

REQUEST FOR PRODUCTION NO. 69

All DOCUMENTS reflecting, concerning, or consisting of communications between anyone representing the Zahau family, on the one hand, and the CORONADO POLICE DEPARTMENT, on the other hand.

REQUEST FOR PRODUCTION NO. 70

All DOCUMENTS reflecting, concerning, or consisting of communications between any member of the Zahau family, on the one hand, and the SAN DIEGO COUNTY SHERIFF, on the other hand,

REQUEST FOR PRODUCTION NO. 71

All DOCUMENTS reflecting, concerning, or consisting of communications between anyone representing the Zahau family, on the one hand, and the SAN DIEGO COUNTY SHERIFF, on the other hand.

REQUEST FOR PRODUCTION NO. 72

All DOCUMENTS reflecting, concerning, or consisting of communications between any member of the Zahau family, on the one hand, and the CALIFORNIA ATTORNEY GENERAL, on the other hand.

REQUEST FOR PRODUCTION NO. 73

All DOCUMENTS reflecting, concerning, or consisting of communications between anyone representing the Zahau family, on the one hand, and the CALIFORNIA ATTORNEY GENERAL, on the other hand.

REQUEST FOR PRODUCTION NO. 74

All DOCUMENTS reflecting, concerning, or consisting of communications between any member of the Zahau family, on the one hand, and the CALIFORNIA DEPARTMENT OF JUSTICE, on the other hand.

REQUEST FOR PRODUCTION NO. 75

All DOCUMENTS reflecting, concerning, or consisting of communications between anyone representing the Zahau family, on the one hand, and the CALIFORNIA DEPARTMENT OF justice INTERROGATORY NO. 12.4

Do YOU OR ANYONE ACTING ON YOUR BEHALF know of any photographs, films, or
videotapes depicting any place, object, or individual concerning the INCIDENT or plaintiff's injuries? If so, state:

Responding Party did not pay a portion of either burial or funeral expenses for the
DECEDENT. As to this Responding party's knowledge, Jonah Shacknai paid for burial and funeral expenses for the DECEDENT.

REQUESTS FOR ADMISSIONS TO MARY ZAHAU-LOEHNER:

INTERROGATORY NO. 2.8

Have you ever been convicted of a felony? If so, for each conviction state:

(a) the city and state where you were convicted;

(b) the date of conviction;

(c) the offense; and

(d) the court and case number.

As part of the instant motion, Mr. Shacknai is asking the Court to award sanctions, At my direction, a member of Winston & Strawn LLP's accounting department provided me with acalculation about the number of hours spent on the meet-and-confer process—in which I was personally involved—and in preparing the motion to compel and its separate statement. That number is well in excess of 50 hours. My current hourly rate $870 and I have been a member of the California bar since 2000. But the rates of my colleagues who prepared the motion and separate statement—one of them who has been practicing since 1999 and the other who has been practicing since 2008—are less; their rates average $470. Based on the findings in the Rulings on I) Motion for Final Approval of Class Action Settlement; 2) Motion for Award of Fees and Class 10 Representative Enhancements; 3) Motion for Leave to Intervene and for Attorneys' Fees; and 4) Motion to Vacate Stipulated Protective Order in Lockabey v. Am, Honda Motor Co., No. 37-2010- 12 00087755-CU-BT-CTL (San Diego Superior Court, decided Mar. 16, 2012), available at 2012 WL 13 5305201, it appears that $470 would be in line with a conservative estimate of the prevailing rate in San Diego for attorneys with similar experience. Multiplying $470—by 50 hours equals $23,500. Therefore, Mr. Shacicnai is seeking reimbursement of reasonable attorneys' fees incurred in this amount

_________________
Keywords: Rebecca Zahau, Suicide, Max Shacknai, Dina Shacknai, Nina Romano, Adam Shacknai, Lawyer Keith Greer, Mary Zahau Loehner, Pari Zahau, Doug Zahau, Coronado, Spreckels


And just so it's clear to anyone who reads my posts, these are my personal thoughts, opinions and questions only.
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 Post subject: Re: AS Wants Answers from Zahaus + Greer, + $23,500 in Sanct
PostPosted: Wed Mar 01, 2017 9:10 pm 
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Just in case any of Adam's lawyers are reading and they want to question Kathleen McKenna as to whether she was given any Privileged files, here is where she says she worked on the case with Anne "Mediaho" Bremner:

Quote:

Part of Guest post by Kathleen (McKenna) Hewtson


I even considered writing a book about Betty myself – after all, I had met her and I had read every book about the case, and I knew San Diego well. Hell, I had even been bundled aggressively out of the presence of Sherriff Billy Gore there for asking impertinent questions about his handling of the Rebecca Zahau murder case on Coronado Island, off San Diego...

...As it happens, a close friend of mine is Anne Bremner, one of America’s top criminal lawyers and legal analysts – the one who got Amanda Knox out of prison in Italy. We had worked together on the Rebecca Zahau case – would she be interested in representing Betty in getting her a new parole hearing?


http://www.retrokimmer.com/2017/01/bett ... guest.html




Kathleen has been a core member of the murder posse that has done their best to frame the Shacknais and Nina Romano. Sure would like to hear what she has to say under oath.
8)

_________________
Keywords: Rebecca Zahau, Suicide, Max Shacknai, Dina Shacknai, Nina Romano, Adam Shacknai, Lawyer Keith Greer, Mary Zahau Loehner, Pari Zahau, Doug Zahau, Coronado, Spreckels


And just so it's clear to anyone who reads my posts, these are my personal thoughts, opinions and questions only.
CuriousGeorgia has been thanked by:


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