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Pastimes : Gary Dobry Subpoenas 41 SI Aliases -- Ignore unavailable to you. Want to Upgrade?

To: scion who wrote (602)	10/26/2002 6:38:13 PM
From: scion	Respond to of 1136

The continuing saga – Part 50 Reformatted for easier reading – errors in the ‘original’ have not been corrected. Q Anyway, Mr. Marvin has, in fact, paid some, if not all of the legal fees have you incurred in this action, is that not correct? A Mr. Marvin has paid zero amount of my legal fees in this case so, no, that would not be correct N. that's ludicrous. Q Has any third party paid some or all of the fees you have incurred in this case? A No. Q The funds for your defense in this litigation have come from your personal assets? MR. RICHTER: I'm going to object to that. It's intruding into attorney-client privilege. MR. ARGENTAR: You're directing him not to answer? I presume. I'm not putting words in your mouth. MR. RICHTER: I'm thinking about it. I mean, I'll listen to, if you think there's some reason why this is an appropriate inquiry, I'll listen tot but other than that I don't think it's appropriate for him to answer that. BY MR. ARGENTAR: Q I'll withdraw question as long as you confirm that no other third party has paid any portion of the legal fees you've incurred in this action, correct? MR. RICHTER: I'm going to object to that as an ambiguous question. I'm going to object to it as intruding into attorney-client privilege and, you know, it's not clear what third party means. I don't object to your asking him, you know, did Mr. Marvin pay any of your legal fees. I don't object to any of that. MR. ARGENTAR: Well what's the distinction between Mr. Marvin and any other third party. MR. RICHTER: I don't know what any other their party means. BY MR. ARGENTAR: Q Any other individual or corporation, other than Mr. Marvin and yourself, have they paid any or all of the legal fees you have incurred in this pending action? A Mr. Marvin has paid zero money towards any legal fees whatsoever. Q Have you ever referred in conversation, or email messages as Jay Marvin as your benefactor? A Yes. Q What did you mean by that? A Jay was -- I met Jay when he bought paintings of mine. He's an act collector. MR. RICHTER: Just answer the question. THE WITNESS: But Jay is a really good guy is what I'm saying. Jay saw what I was going through and he donated -- to find out about the people who stalking me and harassing and invading my privacy. He donated some money towards P.I. bills and, you know, he did help me paid some P.I. bills to help me discern who was stalking me so for that I have a lot of gratitude towards Mr. Marvin. Q So he's paid for the services of private investigators to investigate whom. A He donated some funds -- I'm not sure of the amount. I think $10,000 toward the P.I. bills that -- oh, they include Michael Zwebner, just people for my book, and people who are stalking me. Q These are private investigators have you retained? A Yeah. Q And Mr. Marvin has paid for some of the services of the private investigators you have retained, right? A Right. Q And these private investigators, they have investigated Mr. Marchese; isn't that correct? A Oh, yes. Q And they have, in fact, gone to his residences; is that correct? A We were trying to discern where his residents are. That's what they were retained for. You can see Mr. Marchese won't give any discovery, so I paid P.I.s to obtain this information for me. Q The activities of the private investigators you've retained to investigate, amongst other people, Mr. Marchese, that has occurred subsequent to the filing of this litigation? A I believe it started with Zwebner. So you know, I really don't know. I mean, I've used multiple investigators and they've gotten multiple things from me and started before -- well, you know Zwebner is an associate of Marchese. So it started when I started getting sued by these guys, you know so it starts then.