A: Hepburn was frustrated that all motions and lawsuits she had filed, and all of the warrants that had been issued were not affording Don with physical possession of Doni and securing my arrest. In an effort to goad me into making an appearance to secure my arrest Hepburn scheduled me for a deposition. My attorney personally appeared. I appeared by phone. Hepburn’s deposition notice did not prohibit a phone appearance.
A: Hepburn admitted to noting the deposition to “goad me into making an appearance” and to secure my arrest in an affidavit.
On the day of the deposition, when my attorney appeared at Hepburn’s office at the time noted, there were law enforcement personnel present in the lobby prepared and ready to secure my arrest should I appear.
Because Hepburn’s stated purpose for noting the deposition was to secure my arrest she saw no need to be present at the deposition and had handed it off to a junior attorney in her office. This junior attorney halted the deposition to inform Hepburn that I was making a telephonic appearance at the deposition after which Hepburn immediately struck the deposition claiming “telephonic difficulties.” Neither my attorney, the junior attorney, the court reporter, nor I were aware of any “telephonic difficulties” however.
In the affidavit she filed with the court after striking the deposition, Hepburn admitted to striking the deposition after consulting with the law enforcement personnel present in the lobby of her office and being told that a telephone tap would not be possible. Reference: KCSC Cause No. 88-2-06110-6, Hepburn’s affidavit titled “Plaintiff’s Memorandum in Support of Award of Damages 5882F” at p. 7, wherein Hepburn states: “At the deposition a phone call was received from a person claiming to be [Janelle]. [I] was in contact with the FBI at this point to attempt a telephone tap.”
Hepburn’s “telephonic difficulties” had nothing to do with an improperly working telephone. Just as Hepburn’s refusal to give me notice of the family law hearings via my forwarding address enabled her to pursue a default in the matter, her striking of the deposition also had everything to do with keeping me from making an appearance by phone so she could continue to pursue a default despite the presence and appearance of my attorney.
A: As a result of Hepburn’s ruse to have me arrested at the deposition in the family law matter, my attorney obtained a court order directing that all of Hepburn’s future discovery requests in the family law matter be submitted in the form of written interrogatories.
A: No. Shortly after the order was issued, in November, 1988, Hepburn telephoned my attorney demanding that he appear in the Presiding Department of King County Superior Court within one hour of their conversation. Her stated purpose was for settlement of the family law matter, though she had not discussed any settlement with my attorney, had not provided my attorney with any paperwork relative to a settlement, nor had she given my attorney notice of any settlement hearing in the Presiding Department. Given the gravity of the situation, however, and the possibility of a resolution, my attorney rearranged his schedule to comply with Hepburn’s demand.
