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UNITED STATES BANKRUPTCY COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION In re: CASEY MARIE ANTHONY, Debtor. ____________________________/ DEBTORS SUPPLEMENTAL MEMORANDUM CONCERNING MOTIONS TO LIFT STAY Debtor, Casey Marie Anthony (Ms. Anthony), hereby supplements her response to the Memoranda (Doc. Nos. 89 and 90) she filed in response to the Motions to Lift Stay filed by Zenaida Gonzalezs (Doc. 69) and Roy Kronk (Doc. 68). This Memorandum also addresses the Chapter 7 Trustees Suggestions on Procedure (Doc. 107), which is related to the foregoing filings. 1. Introduction The gist of the motions to lift that is stay it would be more efficient if the stay were lifted so that the claims of Gonzalez and Kronk could be tried in State court. In fact, the opposite is true. Ms. Anthony will not reiterate the facts that have been the subject of her prior filings, but a review of the record demonstrates without doubt that there is no trial set in either case and it would be many months -- and likely many years given the appeals that would ensue from any adverse judgments -- before any proceedings returned to State court were finally resolved. The far more efficient process to resolve this matter is for this Court to address the dischargeability issues first, as the Trustee apparently suggests. In that regard, the Court should require the present movants to file claims if they wish to pursue them. Case No. 8:13-bk-0922-KRM

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2. The Claims At Issue The motions to lift stay were filed by Zenaida Gonzalez and Roy Kronk, Neither of those alleged creditors have filed claims. Instead, they have sought leave to delay doing so because Ms. Anthony has made no secret that she would respond to any such claims by filing motions for summary judgment that she believes would eliminate the claims as a matter of law. A. The Gonzalez Motion Gonzalezs Motion conveniently overlooks or understates three critical facts. First, the State case would have been over in January of 2013 if Gonzalez had not moved for a continuance on the eve of trial. Instead of going to trial, Gonzalez sought to delay the case until after the date it erroneously perceived Ms. Anthonys Fifth Amendment rights would expire. Second, because the Gonzalez State-case was taken off of the trial docket, it would be many months, and probably no earlier than mid-20l4, before the case could be rescheduled for trial, even if the stay were now lifted. In fact, numerous motions were still pending in Gonzalez on the date the petition was filed, including motions to compel, a motion to strike a request for punitive damages, and a myriad of motions directed to the evidence that would be permitted at trial. Third, and perhaps most importantly for present purposes, Judge Munyons Summary Judgment Order threw out the bulk of Gonzalezs claim. Judge Munyon ruled that Ms. Anthonys statements to law enforcement on July 16, 2008, cannot be the false statements that form the basis of plaintiffs claims, Order, p. 4. She held that the sole issue remaining to be determined was whether a single sentence uttered by Ms.

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Anthony during a forty-five (45) minute jailhouse meeting (recorded over the jailhouse video visitation system) between Ms. Anthony and her mother was of and concerning Plaintiff or was otherwise defamatory, and, if so, what damages Plaintiff suffered from that statement. The pertinent statement that Ms. Anthony made to her mother was that when [the Orange County Sheriffs Office] went and interviewed that girl down in Kissimmee, they never showed me a picture of her. Judge Munyon viewed this fragment of a sentence as susceptible to two competing inferences, both of which are reasonable. Summary Judgment Order, at p. 3. The express holding that the statement at issue is susceptible to two competing inferences, both of which are reasonable, eliminates as a matter of law the possibility it could give rise to a liability that would be non-dischargeable. Therefore, this Court should not delay this proceeding by lifting the stay so that it can return to State court where judicial resources will be wasted and the rights of Ms. Anthony under Title 11 of the U.S.C. will be, at best, delayed, because that, even if Gonzalez won, she would still have a non-dischargeable claim. B. The Kronk Motion Kronks prospective claim is spurious on its face. In all events, service of process was never effected in that case and a trial of that matter, assuming Kronk was able to get past the motion stage, would not occur until late 2014 or sometime in 2015. This Court should address this spurious claim now.

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3. The Trustees Suggestions The undersigned views the Trustees recently filed proposal as suggesting that the Court first determine whether the claims at issue would be dischargeable. If the claims are dischargeable, there would be no need to address liability. If that is what the Trustee suggests, Ms. Anthony agrees, subject to the following caveat: to some extent, the liability and dischargeability issues may be inseparable. In other words, the court may have to examine whether there is a legal basis for finding liability before it even gets to the dischargeability issue. If the answer to the first inquiry is no, the Court will not have to inquire further. 4. Kronk and Gonzalez Should Be Compelled to File Claims There is more than ample evidence in this record for the Court to find that the claims of Gonzalez and Kronk are motivated by a perverse quest for publicity that surrounds those involved in the Casey Anthony saga. Their admission in the press and elsewhere show that they are on a crusade to vindicate the public (and get some free advertising in the meanwhile) rather than using the courts for permissible purposes. The Holy Grail sought by counsel for Gonzalez and Kronk is that they want to be the first to break Casey Anthonys story, or at least put her through a televised public proceeding where she will be pilloried while she asserts her Fifth Amendment rights to remain silent. Kronk and Gonzalez understandably want their claims to proceed in State court, where they have the advantages of cameras in the courtroom and relaxed legal principles, such as a standard for summary judgment that is almost impossible to meet, where parties are allowed to create issues of fact based upon inferences from arguments, rather than

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required to present concrete proof showing there is a really an issue that justifies a trial. However, Ms. Anthony, the courts, and the public coffers have suffered far too long as a result of the legal shenanigans of Gonzalez and Kronk. Ms. Anthony respectfully requests as follows: that the Court order Kronk and Gonzalez to file their claims if they want to pursue them. Ms. Anthony will then have the opportunity to either prove her contention that the Gonzalez and Kronk claims are baseless. She will do so by immediately filing summary judgment motions supported by legally cognizable evidence. If Gonzalez and Kronk really have evidence to support their claims, they will then have the opportunity to present it. If they fail in that endeavor, then the Court will be able to bring this proceeding to a prompt close. If they should present sufficient evidence for this matter to go further, the Court can then determine whether and where it should be tried. A party moving to lift the automatic stay must show cause for such relief to be granted. See 11 U.S.C. 362(d). In determining whether such cause exists, the courts employ a totality of the circumstances test, which essentially involves weighing and balancing the possible prejudices to the parties and bankruptcy policies favoring the expeditious and efficient resolution of disputes. See In Re Nofziger, 2007 WL 1047067 (11th Cir. 2007); In Re Aliosi, 261 B.R. 504, 508 (M.D. Fla. 2001). Requiring Gonzalez and Kronk to file their claims in this Court would be, by far, under the totality of circumstances, the most efficient and fair manner in which to handle these matters.

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5.

Conclusion

This is a Chapter 7 proceeding. Ms. Anthony has no assets. The fact that Kronk and Gonzalez continue to pursue their claims prove they have motives that have nothing to do with collecting those claims and nothing to do with justice. Chapter 7 proceedings should be resolved quickly. If the stay is lifted and the State court proceedings continue, this proceeding will drag on for years. Gonzalez and Kronk will be happy, because their fifteen minutes of infamy will continue. Their counsel will be happy, because of the free advertising that they will get from their Crusade for Justice. The press will be happy. And the prurient interest of the public, which will hang nightly on every word written and spoken about Ms. Anthony, will be satiated, at least for a little while. But the courts will suffer. Their resources will be taxed and other proceedings with just causes will be delayed while Nancy Grace and Geraldo scramble for the best seats. The taxpayers will suffer, because they will pay for the judges and clerks and court security and courtrooms and other expenses that will steal from the public pocketbook even more. Casey Anthony will suffer. She will either defend the cases or be forced to default because she has no money. She will be lampooned in the press. The death threats will again increase. She will be forced to find new accommodations, or just simply disappear and say it is not worth the fight any more. Justice will also suffer. In the end, society will be no better. We will have learned nothing. We will be left with an empty space, at least until the next media created personality fills it.

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This Court has the jurisdiction, power and authority to expedite this case and promote the ends of justice. If Kronk and Gonzalez have legitimate claims, they should file them. If they have evidence to support any claim they file, they will have to present it. The Court should compel any such claims to be filed and make a determination as to whether they would be dischargeable, before it makes a decision that could subject this Ms. Anthony, this State, and this Nation to a spectacle that needs to come to an end. Respectfully submitted this 10th day of June, 2013.

/s/ David L. Schrader David L. Schrader Florida Bar No.: 0183943 David L. Schrader, Attorney at Law First Bank Building 111 Second Avenue NE, Suite 901 St. Petersburg, FL 33701 Telephone: (727) 456-5772 Facsimile: (727) 456-6454 Email: dschraderlaw@gmail.com

Debra L. Ferwerda Florida Bar No.: 089419 Jacobson, McClean, Chmelir & Ferwerda, P.A. 351 East State Road 434, Suite A Winter Springs, FL 3270 Telephone: (407) 327-8899 Facsimile: (407) 327-3019 E-mail: dferlaw@cs.com Counsel for Debtor

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CERTIFICATE OF SERVICE

I HEREBY certify that a true and correct copy of the foregoing document has been emailed to Stephen L. Meininger, Trustee at slmeininger@earthlink.net; Allan Watkins, Esq. allan@watkinslawfl.com; the office of the United States Trustee at

USTPRegion21.TP.EFC@USDOJ.GOV , R. Scott Shuker, Esquire, Latham Shuker Eden & Beaudine LLP, rshuker@lseblaw.com; Casey M. Anthony c/o Charles M. Greene, Esq. and Charles M. Greene, Esq., cmg@cmgpa.com this this 10th day of June, 2013.

/s/ David L. Schrader David L. Schrader