The continuing saga – Part 49 Reformatted for easier reading – errors in the ‘original’ have not been corrected.
Q Other than what you testified to do you have any additional evidence that Mr. Marchese has directed people to post online?
A I have banker's box full of stuff. I have to go look through it.
Q You do. Have you turned those over to your counsel?
A I'm not say they all pertain to the case. I'm a writer. I don't know what's in there about Marchese. I have tons of stuff. I mean if I didn't turn it over to counsel, I would go through the box and see what's pertaining to him.
Q Marchese, in this litigation has requested that you produce all documents?
A Mm-hmm.
Q Okay which are in your possession which refer, relate to him?
A Mm-hmm.
Q Okay. ? And you're saying that there may be documents in your possession that you have not produced that are responsive to a specific discovery request? A I don't know. I mean I'm a writer. I collect a lot of research on Marchese. I don't know. I'll go look through my stuff and see and if there is, I will give it to Tobin and he will give it to you.
Q It's apparent from your testimony today that at minimum there's a large possibility that there are responsive documents which have not been produced during the past year. Excuse me?
A Well, you're saying that. I didn't say that. You're trying to put words into my mouth, I didn't say that.
Q Excuse me?
A You're excused.
Q And I will reiterate that we are requesting that the production be immediately supplemented for any of these records that the deponent has referred to, which may exist. If they don't, fine?
A All right.
Q I want them, and we're going to reserve the right to redepose you regarding any additional documents.
A Will you come up with some defamation then?
Q It is alleged in the amended complaint filed in this suit that you have directed other people to post messages on the Internet regarding Mr. Marchese. You are aware that is an allegation in the amended complaint?
A Mm-hmm.
Q Yes?
A Yes.
Q You know a gentleman by the name of Jay Marvin do you not?
A Mm-hmm.
Q Is that a yes?
A I'm sorry. Yes. I do know Jay Marvin.
Q And Jay Marvin who is a radio personality at WLS radio?
A Well, since that's where you're the sending threatening letters, yes.
Q What -- what are you referring to?
A Joseph Piterra's letters to his boss.
Q What are you talking about?
A Nothing. They're discoverable. Ask Jay when you depo him.
Q You say he's sending threatening letters. Are you referring to -- who is sending threatening letters? A I don't remember. Go look at the Internet. It's all out there. Your boy Scion is posting about it.
Q When you say Scion, who are you referring?
A My belief or.
Q No. You just referred to somebody. Who are you referring to?
A The ACLU protected Scion. The only thing I know is two signatures were given in their motion to quash, that two people appear to be posting as Scion. I don't know who they are, unless you do it. |