A: Upon my attorney’s arrival at the courthouse he realized that Hepburn had perpetrated another ruse, this one to avoid her having to comply with the discovery order the court had issued in October.
A: There was no purpose in submitting interrogatories as the gathering of discovery was not her purpose or intent.
A: Hepburn’s idea of a settlement was to ask the court to award Don default custody of Doni. She based her request for default custody on my (alleged) failure to participate in discovery proceedings in the family law matter, i.e., my failure to appear at the deposition she had struck due to “telephonic difficulties.”
The Presiding Judge ruled that Hepburn could not substantiate her claim that I had failed to participate in discovery proceedings in the family law matter and denied her motion for default. Rather than requiring that Hepburn comply with the court order that discovery be conducted via written interrogatories, the Presiding Judge sent the matter to the Family Law Department for hearing that afternoon.
At the afternoon hearing, FLC DuBuque voided the discovery order and ordered my personal appearance at a second deposition to be noted by Hepburn.
Hepburn wasted no time in noting a second deposition. My attorney appeared at this second deposition. I did not as it was clear Hepburn’s intent was to secure my arrest and gain physical possession of Doni, not gather discovery.
A: No because it was not entered by her.
A: Yes. On December 30, 1988 FLC DuBuque relied on her (post-dated) March 11, 1988 order to enter an Order of Default. However, in the affidavit Hepburn submitted in support of her motion for the default dated December 29, 1988, Hepburn admitted that there was NO attempt by her to give me notice of the March 7, 1988 hearing at either my forwarding address or through my friend during her deposition, claiming it was not her responsibility to impart notice of the hearing to me “through the grapevine.” Reference: Cause No. 82-3-05162-8 and 88-2-06110-6.
There were no requisite Findings of Fact and Conclusions of Law entered.
There was no provision in the December 30, 1988 Order of Default protecting or affording me any parental rights.
A: Absolutely not. An in-depth discussion of this is contained in “The Positions of the Judiciary and Applicable Law” section above, as well as in the Q&A section below involving the appellate decisions and King County Superior Court Judge Robert Dixon’s May 3, 1989 Order of Dismissal.
