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T IN THECIRCUIT URT FT HEF I RSJ UDI CI A L RCUI T CO O CI IN AND FOR ESCAMBIA COUNTY, FLORIDA R E:TH E ARRIA GE M OF: JACKIE

.C AME RON R Petitioner/H nd, usba NO: CASE 2012-DR-1993 and C H R ISTINE ME RON S.CA Respondent/Wife.

FOR DISQUALIFICATION RESPONDENTS SECOND AMENDED VERIFIED MOTION JUDICIAL PURSUANT FLORIDA TO STATUTE 538.10and (e), ADMINISTRATION 2.330(dX1), (f) and (i). FLORIDA RULES JUDICIAI OF TO RESPONSE INCLUDING AND MEMORANDUM LAWAND REBUTTAL PETITIONER'S OF NOWRespondent, CHRI S T I NE ME RO N, ro u g hCHRI S T I NE CO O K, L C , S .CA L C OME S th S UE p u r su a nto Florida tatute t Ru o S and t h e F lo rid a le s f J u d ic ia lA d min is t ra t io.n 3 0 ( d ) ( L ) , 2 3 538.10 (e),(f) and (j) and movesto disqualify Thomas Santurri Circuit R. as CourtJudgeand to change FL ven u eto Alachua Duval or County, i n t h is ma t t e ra n d in s u p p o rt h e re o fs t a t e s : t INTRODUCTION L. On JuneL9,2012,Respondent filed a Motion for Change Venuealleging, of

that shefearednot receiving fair trial in front of Judge a Thomas R. amongother things, Florida.On May 25,20L2,Petitioner, Santurriand/orin Escambia SantaRosa or Counties, when informing Respondent that he filed for divorce two daysprior alsotold her that he "talkedto the judge" and that he already knewthe outcomeof this case. (Todate,everything has Peti tio n ethreatened occurred.) r 2. Because lackof fundsfor legalfees,Respondent forcedto withdrawher of was

of 7, acti onfor change venueon A ugust 2 O L 2 n d a c q u ie s cte ju ris d ic t io n t h is c irc u it .Si n c e a o in

ThomasR. that Judge below,it hasbeenegregiously obvious that date,and as described hopedto 26,2012,Respondent until November however, has Santurri favoredPetitioner; receive fair trial. a FACTS 3. on 6,20L2, filed simultaneously December Noticeof Appearance, Respondent's

"A." heretoas Exhibit is Disqualificationattached VerifiedMotion for Judicial with the original 4. and wassigned Ann E.Meador,Esq. by of A Stipulation Substitution Counsel for

14, Thomas Santurri December R. on byJudge and the Orderwassigned S. Christine Cook,Esq. "8." heretoand incorporated Exhibit as 2OL2.SaidOrderis attached 5. it that Thomas Santurri, was obvious R. Before this casewas evenbeforeJudge

on At favorto Petitioner. the time of settingthe hearing hisAmended his officewas currying Petitioner, then and now a pro se litigant, and Temporary ChildCustody, Motionsfor Contempt Wh 'a the g wa s pe r m itted schedule samew it h o u tc o n s u lt in Re s p o n d e n tcs le n d a r. e n to of Respondent called Judge Saturri's officeto inquireasto the scheduling the August7,2012, werepro se litigants, she that both sheand Petitioner hearing and to alertthe judicialassistant would not be rescheduled. in terms,that the hearing was informed, no uncertain 6. for Spencer, testifying the Petitioner, In that hearing August7,2012,Dr. Rick on

for Santurri and both parties conversation, whichJudge informedthe Courtin an off-record age that to removean infantof Minor Child's from his motherfor more than a were present, to 48-hourperiodwould be detrimental the childnot only now, but in the future and forever. qualified "expert")testified, (whomJudge Judge Santurri an After Dr.Spencer Santurri five (5) care removed the Minor Childfrom the Respondent's and placedhim with Petitioner

daysa week. 7. heardtestimony from ln the hearing August7,2012,Judge on Santurri

from Petitioner, including Respondent the physical, of emotional and other abusesuffered physical violence when Respondent pregnant was and twice while Respondent holding was journalentriesand by email wascorroborated Respondent's by Minor Child.Thistestimony Judge exchanges betweenthe parties.Evenafterthis testimony, Santurri orderedMinor Child to the careof Petitioner, without supervision. 8. At the August7,2012,hearing, Respondent testifiedabout Petitioner's illegal

drug abuse(cocaine and illegally-obtained Lortab).Furthermore, Petitioner a well-known has (a habit in the community fact of whichRespondent previously drug (cocaine) was unaware). In lightof all of thesefactsand evidence, Court,in summary, the rationalized that "evenif Mr. was [using Cameron cocaine] duringthe face-time the childwaswith Ms. Cameron so, [sic], the r e for ethe childwasnot in danger. . .a n d p la c e d h e Min o r Ch ild h P e t it io n ewit h ou t , " t wit r page93, lines1-7 orderingsupervision drugtesting. (Transcript August7,2012 Hearing; or of (portionattached).) 9. On August7,2OI2,in the hearing, Judge Santurri heardof the five (5)times

Peti tio n ecancelled r visits with Minor C h ild .P e t it io n e r, e n s c h e d u lintg e s ev is it s , wh h demanded soleuseof one of Respondent's family's home,and arrangements were madeby Respondent's familyto vacateone homefor thosetimes Petitioner wantedto visitwith Minor page59, lines22-25and page70 linesL-11 Child. (Transcript August7,2012 Hearing; of (portionattached).) Thomas Santurri Judge R. failedto take into account thesefailedvisitsor the effortsRespondent, her family,madeto facilitate and same.

10.

daily heard of Santurri testimony Petitioner's 7,20L2, Judge OnAugust

of minutes day. (Transcript a to with involvement and/orinteraction MinorChild wit:fifteen page lines 76, 1-4 attached).) Hearing; 75, 21-25 page lines (portion and August 7,LOLZ
11. hearing Petitioner informedthat Courtthat his ln the August7, 2AL7, specifically

actions were meantto punishRespondent, soughtCourtto removeMinor Childfrom her and page29, line 19-25(portionattached).)Judge care. (Transcript August7,zOtZ Hearing; of Thomas Santurri, R. ignoring bestinterests the then 9-month-old the of to baby,acquiesced Petitioner's demands and awardedmake-up time to Petitioner, rejected of the evidence all and the experttestimonyin favor of Respondent. L2. On August24,20L2,afteryelling"fuckyou" at Respondent while Respondent

was holding the Minor Child,Petitioner told Respondent it was "not [his]fault that the that judge punished you." 13. ln Respondent's hearing November on 9,2012,on her Petition Temporary for

job Relocation, JudgeSanturriheardevidence Respondent's offer as an attorney in Fort of plusbenefits, Lauderdale earning annualsalary 568,000, an of including healthinsurance for Minor Child(who is now on Medicaid). Judge heardevidence the educational Santurri of opportunities amenities and available Minor Childin SouthFlorida, to and learned the of family,professional social and relationships Respondent, livedin the areafor over of who twenty years, and is the areato whichshedesired returnwhen she met Petitioner.(Onthe to date of this hearing, Petitioner had refused pay Respondent to childsupportand had not premiums.Respondent exactly reimbursed for life insurance her had in 522.87 her checking acco u n t.)

personal Petitioner stated knows he information about Judge Santurri wit: "Judge to Santurri is (said a Yankee" was statement in public recorded Petitioner's and with knowledge). When asked howPetitioner knewsuch information, Petitioner stated that hefoundout on the (floridabar.org); Florida website Bar however, personal no information is whatsoever contained on thiswebsite about Judge Santurri.
L7. On November 26,20L2,in a hearing, Judge Santurri Respondent admonished for

breathing loudlyand then, raising voice,scolded not to "talk back"to him. his her 18. Thomas Santurri alsoshownprejudice Judge R. has toward Respondent's

attorney. In a hearing when Ms. Meadorwas examining Petitioner aboutthe inconsistencies in a sworndocument versus sworntestimony his that day,Judge Santurri, his own volitionand on not by objectionof the Petitioner, instructedMs. Meadorto move on, that her questionhad already been"asked and answered" when,in fact,it had not. 19. As evidence his continuingfavor of Petitioner, of orderson two (2) outstanding

ExParte Motions to CompelPetitioner's Response Discovery (October23,2012 (71, to Requests days)and November t4,2OL2(a9 days)) remainunsigned. Then-counsel Respondent, for Ann E. Meador,Esq. reminded the Courton November proposed 26,20L2, thoseoutstanding of orders.As of this date,Respondent's previous two Motionsfor Judicial Disqualification have beenexpeditiously denied(the first in five (5) days, the second seven(7) days).Petitioner's in discovery responses still outstanding are and no order to compelhis responses been has signed. Moreover,given Petitioner's historyof and current illegaldrug use,a fact of which is known in the communitv, CourtdeniedRespondent's the motionfor drugtestingof Petitioner in seven(7) days.

MEMORANDUM LAW OF 20. FloridaStatute38.10provides that: makesand files [w]henevera party to any actionor proceeding an affidavitstatingfear that he or she will not receivea fair trial in the courtwherethe suit is pending account the prejudice on of judgeof that court against applicant in favorof the of the the or party,thejudgeshallproceed further,but another adverse no judgeshallbe designated.... (F.S.538.10 2OL2.l 21,. provides Florida Rules JudicialAdministration of that a motionfor 5 2.330(d)(1)

disqualification showthat the partyfearsthat he or shewill not receive fair trial or shall a he a r in g .... R.Jud.A dmin.52.330(d X 1 ). Fla. 22. Florida provides Rules Judicial of Administration 2.330(e) that the motionto 5

disqualify shallbe filed within ...ten daysof discovery the factsconstituting of the groundsfor the motion and shallbe promptlypresented the courtfor an immediate to ruling. Fla.R.Jud. Admin.52.330(e). 23. Florida Rules Judicial of Administration 2.330(f) states that: 5 the judgeagainst whom an initialmotionto disqualify is ... directed shalldetermine onlythe legalsufficiency the motion of ...and [i]f the motionis legally sufficient, judgeshall the immediately enter an ordergranting disqualification proceed and no further in the action. Fl a.R.Jud .Admin.S 2.330(f). 24. Legalsufficiency a motion to disqualify of basedon prejudice, defined by the as

Supreme Courtof Florida, whetherthe movanthasa reasonable is groundto fear that he or she wifl not receivea fair trial. Livingston Stote,441So.2d1083{Fla.1983). v. 25. The SupremeCourt,in Livingston, further statedthat

question raise when of is to but [p]rejudice a judge a delicate judgeagainst prompt whomraised, raised... the should be to recuse No himself. judgeunder circumstances any iswarranted in sitting the trialof a cause whose neutrality shadowed is in or questioned. even
/d. at 1085. 26. Fischerv. Knuckand Detrounoyv. City of CorolGoblesdo not apply in the instant

finaljudgment.497So.2d240 (F\a.1986) 65 So.3d and caseas this matter hasnot reached 1103 (3d DCAJune29,20t1), respectively. 27. Lastly, SupremeCourt in Livingston held that: the requirements the contents the affidavits of need the technical of not be strictlyappliedbut, rather,they will be deemedsufficient "[i]f takenas a whole,the suggestion supporting and affidavits are sufficientto warrantfear on the part of" a party that he will judge. not receive fair trial by the assigned a Livingstonv. Stote, 441. So.2d1083 at !087 , citing Dickenson Parks,194 So.459 v.

(1e32).
REBUTTAL PETITIONER'S TO RESPONSE 28. Petitioner asserts that the original Verified Motion filed on December 6,20t2,

did not containa certificateof counsel that samewas beingmade in good faith and that it was filed by someone not counsel recordin this matter. Christine Cook,LLC, of Sue filed a Noticeof Appearance December 2OL2, on 6, simultaneously the VerifiedMotion and,as such,is with counselofrecord. (SeeExhibit"A."l Further, Paragraph whichcontainsthe see 23 certificate of counsel that the original motionwas madein goodfaith. Said"goodfaith" certificate is included this AmendedMotion in Paragraph the lastand final paragraph. in as Petitioner relies on Parsons Motor Homesof Americo,\nc.,456So.2d1285(Fla.1" DCA1985);however,in v.

v. District So.2d , the Fourth 627 Courtof Appeal specifically addresses the Caleffe Vitale,488 "technical issue technical errors and,in citing Supreme the Courtin Livingston, states nonof factsto with will states sufficient compliance the statute not bara claimwhichotherwise judge." Caleffe fearthat he or shewill not receive fair trial by the assigned warranta party's a at 628,citingLivingston 7087. at
29. Petitioner that the VerifiedMotion filed on December alleges 6,20L2,is not

within ten (10) daysof discovery the facts. As statedin Paragraph of the VerifiedMotion, of 2 Respondent continued hopethat shewould receive fair trial up until November to a 26,2OL2, ThomasR.Santurri her when Judge chastised for takinga deepbreath. Therefore, November 26, 2072,is the date of discovery the prejudice. of 30. Petitioner beeninformedsinceSeptember 2AL2, has 5, that all future

with him will be, and are audio recorded. Respondent encounters was forced to do so after Petitioner chased aroundMinor Child's her doctor's waitingroom on August27, 2OI2,calling her a "drunk" and a "slut" and yelling"fuckyou" to her whileshewas holdingMinor Child. ln emaifs datedNovember t5,2012, at 2:33PM CTand 4:L8 PM CT,Respondent informed Petitionerthat he would be recordedand therefore,Petitioner's assertion that he was without knowledge much likethe restof histestimony, lie. SeeExhibit attached is, a "C" hereto. 31. Petitioner, suggesting the Courthasno obligation consider in that to the

"subjective" fear of the Respondent ignores the rulingof FloridaSupremeCourtcaseof Livingston Stote,441So.2d1083 (Fla.1983). The Livingston v. court held that the party seeking to disqualify judge needonly show"a well grounded a fear that he will not receive fair trial at a the handsof the judge...."" CitingStoteex rel. Brownv. Dewell,179So.595, at 697-698(1-938).

The Livingsfon Courtwent alsonoted that "it is a questionof what feelingresides the in affiant'smind and the basisfor suchfeeling,"hence thesubiectivefearof the litigant is directly at issue./d. (Emphasis added.)

coNctustoN
32. Petitioner an attorneyand practices Escambia SantaRosa is in and Counties, and

hasdone so for at least13 years. Moreover,Petitionerwas born and raisedin pace,Florida and professes know everyonein both counties. Priorto takingthe bench,JudgeThomasR. to Santurriwas a FloridaBar BoardCertifiedFamilyLaw practitionerin SantaRosaand Escambia Counties practiced and presumably alongsidePetitioner.Moreover, Judge Santurri has presidedover Petitioner's cases, includingPetitioner's forfeiture of the firearm that was seized duringhis 2005felonyarrestfor possession cocaine (2005CF1139, of SantaRosa County, Florida). 33. Respondent an attorneywho hasno disciplinary is history(Petitioner's Florida

Bar historyis repletewith reprimands and admonishments), no felony arrests, has does not use or abusedrugs* illegal otherwise and hasbeenan exemplary or motherto Minor Child. Nothingin the record,or otherwise,supportsJudgeSanturri's rulingsfavoringpetitioner, excepthis prejudice against Respondent. 34. Because the aforementioned of reasons, Respondent remainsfearful that she

will continue receive unfairtrial. to an Under penalties of periury | declarethat I have read the foregoing SecondAmended Verified Motion for JudicialDisqualification includingMemorandumof law and Rebuttalto Petitione/s Response thereto, and the facts allegedare true and to the best of my

10

knowledge and belief.

CHRISTINECAMERON S. STATE FLORIDA OF COUNTY ESCAMBIA OF

20ta ,,/ personally by meor who 2+2;by Christine Cameron, is v known S. who
Florida Driver's License C565-117-69-682-0identification. as

The foregoing instrument acknowpdged was before onthisme

o^,

"WoM
produced

\'/

NOTARY PUBLIC,T

Printed Name: u Y- l+otnlQr/\ l'nul


Commission expires: ltl _.,94.tj

,,

i.Bf; ; .'6ti::3.i3 ii i', "1,1"

WHEREFORE, Respondent respectfully requests Honorable this Court:


a. find this VerifiedMotion for Judicial Disqualification legally and sufficient

judgeof this matter;and and immediately recuse himself presiding as b. grantthe incorporated VerifiedMotion for Change Venueand direct of

the Clerkof the Courtto reassign this caseto Alachua DuvalCounty. or THISSECOND AMENDED VERIFIED MOTIONFOR JUDICIAL DISQUALIFICATION, INCTUDING MEMORANDUM IAW AND REBUTTAT PETITIONER'S OF TO RESPONSE THERETO IS BEING MADEIN GOODFAITH. I HEREBY CERTIFY a copyof Respondent's that Amended VerifiedMotion ForJudicial Disqualification, including Memorandum Law,Rebuttal Petitioner's of to response theretowas furnished Jackie Cameron, to R. Petitioner, emailat jrod@jrodcameron.com via and liz@jrodcmeron.com to Judge and Thomas Santurri, hand-delivery this 2nd R. by on day of Ja n u a r y 0 13. 2

11

ESQ. CHRISTINECOOK, S. LLC CHRISTINE COOK, SUE FLA. No: 0528439 Bar Street- Suite 109 890 SouthPalafox Pensacola, 32502 FL

(8501572-7Lss fax / (877124e-627e


ristinescook.com christine@ch Attorney for Respondent

I2

IN THECIRCUIT COURT THEFIRsT OF JUDICIAL CIRCUIT IN ANDFOR FLORIDA ESCAMBIA COUNTY. RE:THEMARRIAGE OF: R. JACKIE CAMERON Petitioner./Husband.

CASE 2012-DR-1993 N0:


and S. CHRISTINECAMERON Respondent/Wife.

NgTrcE aj?PFAFANCE oF
COMES NOWthe undersigned attorney and filesthis Notice Appearance for of Respondent Christine Cameron, S, I HEREBY CERTIFY a copyof the foregoing that wasfurnished Jackie to R. Cameron, Petitioner jrod@jrodcameron.com Ann E.Meador,Esq, at and at ann@meadorjohnsonlaw.com christie@meadorjohnsonlaw.com day of and this Gth December 201"2. CHRISTINE COOK, SUE LLC BARNO:528439 FLA 890 SouthPalafox S(reet Suite109 Penldcola, 32502 fL

CHRISTINE COOK, SUE LLC

gqnrnt'4

Electronically Flled 1211012012 PM ET 04:03:53

f t ' ; : lt L [ [ f iA G , il- ] r

coURT AND EScAMBIA:bffhT'-dJffiffiIililT' CIRCUIT IN FoR INTHE


LAW DIVISION FA.MILY RE: The Marriage of JACKIER. CAMERON, Petitioner/Husband.
and

;li: i[f lt i: j, ]0

r r,5'd,j,Hlbrtt,ro
CASENO.:2012DR 001993 DIVISION: L

CH R IS T INS . C A ME R ON, E RespondenUWife.

ORDERFORSUBSTITUTION COUNSEL OF STIPULATED that SUE COOK, The Wife andthe undersigned attorneys' stipulate CHRISTINE for ES Q U I R E ,n dC H R IS T INS U ECOOK, a E as of LLC, substituted counsel r ecor d a nd be for on behalfof the Wife,CHRISTINE CAMERON, and in placeof Ann E. Meador, S. Esquire, Meador Johnson, cause andthatAnn E. Meador, and & P.A.in the above-styled Esquire, Meador Johnson, & P.A.be relieved anyfurther to and of responsibility provide representation behalf the Wife,in thi3action. on of The parties having stipulated,is hereby, so it OR D E R E D N D A D JU DGED A that CHRISTINE SUE COOK, ESQUIRE, nd a CHRISTINE SUECOOK.LLC.are substituted counsel record the Wife in this as of for matter and Ann E. Meador, Esquire, Meador Johnson, P.A.are hereby and & relieved of all fufiherduties and/or responsibilities regard providing with io representation behalf on of the Wife.

oY-hrnA.6

2c5 H$uHHry-

\q5

ChristineS. Cook
From: Sent: To: Subject:

Christine Cook $. [csuecook@gmail.com] Thursday, November 15,2012 PM 4:18


Jrodcam

Re:1 yearcheck up

I am glad you agreeand arefinally telling the truth. You will be recorded. On Nov 15,2012,at 3:23PM, Jrodcam @> Yeah,that'swhat happened. you tomorrow See Sentfrom my iPhone On Nov 15,2012,at2:33PM, "Christine Cook" <csucoook,.agmail.com> S. wrote: you meanwhenyou followedme around callingme a "slut"anda "drunk"and yelling "fuck you" while I washoldingour son? Yeah,I don't want to repeat that. So, if you come,this is your noticethat I'll be audiorecordingthe event. Hopefully,that will remindyou to act like a gentleman.Otherwise, you can ask Dr. Barberfor the records. <jLodcamr?tqmail. wrote: On Thu,Nov 15.2012at 2:15PM, Jrodcam Thankyou. I would like to attendthis appointment, am hesitant given our last but interactionat Dr. Barber's office. I would like to sit outsidcuntil you arecalledbackandthen I will comein. If you just sayso and I will just get the recordpost would preferI not attend,please appointment. JRC wrote:

on Nov|5,20|2,atl:04P M,''Ch ris t in e S . Co o k ' ' @}


wrote: > Smith has a doctor's appointment tomorrow at I 1:00 for his one year well check visit.

xhfi* \\e''

29
1 THE COURT: A (By Mr. more ,Johnson) to You facilitate your between wife you Be admitted testified comrnunication and and the the chiJ-d child; as 4. that or than is your that you are

2 3

also

1ikely

contact

between been

5 6 7 8 9 10 L1 L2 13 L4 15 16 t7 18 19 20 2t 22 23 24 25
A A a A a

wife

has

correct? That's Irm 2012. address? Yes. And that all for in then in this going email, to be you trave told your to your and Do about our son wife limit wife when correct. to show you an emaiJthe dated and August your 4, email

going

Do you

recognize

email

you're

asking

the

judge and only,

comrnunication t,he next three you

between months had and

yourself to no no email face-time, texts

December

have calls you'11

telephone in three

phone months correct.

understand what time I had

my position? requested has is the in Judge to

That's that

That's make-up in fact,

during

the and,

the

Judge

discretion intended J-imit emailmonth the as

make-up measure, between I've had

visitation that the for can the

a punitive

communications as if

parties the do last it,

comrnunications or so. Because

my wife

then

anchorreporters

. com

46

child

sleeps

at that

night. I just

But

if

you about,

had

the

2 3
4 5 6 7 8 9 10 11 1,2 13 L4 15 L6 L7 18 19 20 2t 22 23 24 25

arrangement non-custodial that then untj-l up day you with

spoke

that bit of and years end

parent the

could until

spend

a good time,

chiJ.d

night throughout that complete possible

could age shared you

work four

towards or five

the could

about

you

having So,

parenting know, was that's the

overnight too, to go. that living seven is in if the

time. Court

deemed a chiJ-d months Florida/ aw ay that

that that's old,

right of

way

With eight south miles where or two The

the my wife

age is

my son

currently six or

approximately me. of Is there

hundred scheme

from kind for

a visitation would be

distance

reconrmended the

advised of only us?

my son's

visitation

between

way visits said

that

makes almost if

sense down you week,

is

for

you You to

to know,

have

periodic l-ike time the I

there. were going

before,

make-up about his a

and

spend

a whole of

then

you then

worry from

chi1-d's

sense the

separation may that in this not

mother sense

because of knowing what to,

child if

realJ-y the

get case. case I

you, happened

were

That's referring

other in this

was

where

the

father

anchorreporters

. com

69
L you made to and facilitate the efforts child the since I contact that made? between time? Mr.

2 3 4 5 6 7 I 9 10 1_ 1 L2 13 t4 15 15 L7 18 19 20 2L 22 23 24 25
A A

Cameron What Yes. Since Since WelI, come but and that from I

other

have

a
A

what the okay. to

time? divorce f was he fi].ed? has been not is he for eight could lf he with I've invited down to

a
A

mean

my family's because

home, our so son that

supervision, months help needed whom he to trirr o1d so it

mean

he's he my

a handful, would have

heJ-p rather, or brother

sister-in-Iaw a very invited good him

remains I've to

contact. down several

attempted times. The

Orlando times has Mr. Cameron Smith? canceled plans to

How many exercise Five. Over Five Sure. He canceled of June. the

vi-si-tations

with

a
A

course

of

the you

end J-ike

of

May

to teLl

the

present?

times.

?Iould

me to

you?

a
A

the

visitation

on

the

first from

weekend 6-14 to to south

He canceled He had to already

visitation made the in

6-18. Florida

ride

down

defend

himse]-f

the

domestic

70

violence after

injunction. seeing in slept Smith he an for to for

And only

he

left five two

very and

abruptly a half and realJ-y

3 4 5 6 7 8 9 10 11 T2 13 l4 15 16 17 18 19 20 2L 22 23 24 25
A

hours, Smith onJ-y

which for son

ingested hour four and

Margaritas so he

a ha1f,

saw our

hours. the weekend those my brother he had had of

He was July

suppose ,Iuly with the that

come down 8th.

6 through

He made and and he was

reservations made all

my brother

accommodations, period because that he did

advised down me.

me during specifically

not

coming to see

not

want

a
A

He meani-ng Yes. to f Mr.

your

husband? advised he me that did not he want for so he did to not see want me.

Cameron

come had

down

because made to

actualJ-y

arrangements have Smith

my brother didn't have

and to

sister-in-law see me.

THE COURT: very time. MR. JOHNSON: close to the

Excuse time,

me,

w are

getting of the

conclusion

Yes,

sir. the ability to

(By Mr. reside No. Why not?

Johnson) in the 1ocaI

Do you area

have

currently?

anchorreporters.

com

75

1 2 3 4
A

years had know The

ago broken what incident

that

showed rib like, you

they on

were the so.

healed. side

WeJ-l, and I

another it looks that you

other

have

a1leged that

at

our

wedding/

were

drinking

day?

6 7 I 9 10 11 L2 13 t4 15 t6 t7 18 19 20 2L 22 23 24 25

A I A

No. You Yes. didn't I had the the drink at our wedding but our the the at all?

champagne, day after on

altercation

happened a How about you A A f

wedding. Bayou incident, were

Bands that not to

drinking drinking reg'ards it true over

day? any more than you with I arrived for were. our son, that of

was

With isn't I took

my interactions whenever of our

that the until care

home the rest

son in

the A A No, You would him A I'm is over

evening that's deny feed and not not

you true.

left

May?

not that him,

at I

any

time do

on

the

evenings but

that bathe

would for

everything evening? that come would and

prepare sure true

him

the

how you that with you him.

asked would What come

question, home and

but take

it

duties is

g,eneral]-y I would you go were to

happen the

you

would and

home

computer,

within

15 minutes

anchor

reporters

. com

76

1 2 3 4 5 6
7 8 9 10 11 A a

asking'me you got out rsn't if to you get were about of it

to

look

at the

the

baby to

or, me.

you

know,

that

bringing

baby to

So I

general1y were

15 minutes

myserf

before

you

ideas. true had any that whenever to I r run would wouId such keep arrive as publix and home, or you

errands that errands? do is when that's

groceries, run your

Snith

would f would

generally office And 3:00, f

that

on

Friday open come would then?

afternoons untiJhome go to noon around. publix. on

when

your

actual.J.y you would I

Fridays. 2:0O a A A And or

t2 13 t4
l_ 5 16 L7 L8 19 20 2L 22 23 24 25
A a a A

when our

wouldn't

keep

son

Um-hum. Okay. it true At night, after Smith that we all would would his went bake get to up, up bed, f was give isn,t

whenever the

normally him

person and

and

a bottle not once you

changre every _

d.iaper? time. you gave him a

That's bottle Are

the in

case awhile that care

denying I took

a majority of our son?

of

the

time

after

midnight Yes, okay. to south f

am denying whenever Florida,

that. you made I the decision to that to relocate

did

consent

anchorreporters.

com

93

1 2 3 4 5 6 7 8 9 10 L1 t2 13 t4 15 t6 L7 18 19 20 2t 22 23 24 25

child. abuse have if Mr. of the

There

hasn't

been

real

testimony although But of

as I

to did

controlled testimony was

substances, from Ms.

Cameron. some sort

even a was was

Cameron during

utilizing face-time, therefore, not of

substance with not Ms. in

the so, was

the the

child child an

Cameron and

danger

receiving

appropriate it occurred. So at has Dr. did forth And to to be

standard

cate.

Thatrs

even

if

this

particular to and this f was

point area. vexy

the And glad

child what that he and

returned said, because to

Spencer testify as

everyone time

argues be that

back spent.

how much four, from

should d.ays

me three, old an j-s away

f j-ve either of

a nine appears They contact two seem

month to to be

parent time. the

excessive so much he

amount and they

forget

need the

time. days

What and

sug'g'ested, days, it

two very

days,

three for least

seems

inconvenient chiId. for the At next

everybody at this

except particular according of

for

the stage, to Dr. time the is and

mine

months, a J-ot

Spencer's needed

testimony, both

contact So that's

between

parties.

an ch_o_r-repo: te r s . com

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