Thursday, April 12, 2012

Casey Anthony deposition in civil trial (Oct. 8, 2011))

The following is the transcript of Casey Anthony's deposition in the civil trial: Zenaida Gonzalez vs. Casey Anthony scheduled to begin on January 2, 2013.

1
1 2 IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA
3 ZENAIDA GONZALEZ,
4 Plaintiff,
5 vs. CASE NO.: 2008-CA-24573
6 CASEY ANTHONY,
7 Defendant.
8 ------------------------------------------------------
9 The deposition of CASEY MARIE ANTHONY conducted via
10 videoconference on behalf of the Plaintiff on Saturday,
11 October 8, 2011, beginning at 8:02 a.m., at the law
12 offices of Morgan & Morgan, P.A., 20 North Orange Avenue,
13 14th Floor, Orlando, Florida, and the witness at an
14 undisclosed location, before Laura J. Landerman, R.M.R.,
15 C.R.R., and Notary Public, State of Florida at Large.
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CENTRAL FLORIDA REPORTERS, INC. 407-422-5753

1 A P P E A R A N C E S:
2 3 4 5
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7 8 9 10 11
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13 14
JOHN B. MORGAN, ESQUIRE JOHN W. DILL, ESQUIRE MATTHEW MORGAN, ESQUIRE Morgan and Morgan, P.A. 20 North Orange Avenue -- Suite 1600 Orlando, Florida 32801

For the Plaintiff,

CHARLES M. GREENE, ESQUIRE (via videoconference) Charles M. Greene, P.A. 28 East Washington Street Orlando, Florida 32801
and ANDREW J. CHMELIR, ESQUIRE (via videoconference) Jacobson, McClean, Chmelir & Ferw 351 East State Road 434 -- Suite A Winter Springs, Florida 32708

For the Defendant.
ALSO PRESENT: Jeff Fleming of
Ron Fleming Video Productions David McKeon, IT, Morgan & Morgan
1 I N D E X
2 TESTIMONY OF CASEY MARIE ANTHONY
3 Direct Examination by Mr. Morgan 4
4 CERTIFICATE OF OATH 50
5 CERTIFICATE OF REPORTER 51
6 E X H I B I T S
7 (None marked.)

1 MR. DILL: We have to get the stipulation
2 about the oath since your client is there. Okay?
3 So we're going to go on the record. Is that all
4 right?
5 MR. GREENE: That's fine, yeah.
6 MR. DILL: We're on the record. We just --
7 this is John Dill representing the plaintiff. I
8 just want to confirm we have a stipulation between
9 counsel that the court reporter can administer the
10 oath via this video conference and that will be
11 acceptable as far as a binding oath; is that
12 correct?
13 MR. GREENE: That's correct.
14 MR. MORGAN: Let's let the court reporter
15 swear the witness.
16 - - - - -
17 CASEY MARIE ANTHONY
18 having been first duly sworn via videoconference by
19 stipulation of counsel, testified as follows:
20 THE WITNESS: I do.
21 DIRECT EXAMINATION
22 BY MR. MORGAN:
23 Q Good morning. My name is John Morgan, and I
24 represent Zenaida Gonzalez. I'm going to be asking you
25 some questions this morning. I'm sure you've spent some 
1 time with -- with your attorney. The only thing that I
2 would remind you of is if you would please answer instead
3 of "uh-huh" or "huh-uh" just "yes" or "no." And if you
4 don't understand a question that I ask, I'll be happy to
5 repeat it or rephrase it.
6 Do you understand all that?
7 MR. GREENE: She understands her obligations.
8 Q Would you state your full name for the record,
9 please?
10 A Casey Marie Anthony.
11 Q And what --
12 A I'm sorry. Casey Marie Anthony.
13 Q Thank you. And what is your name -- what is
14 your date of birth?
15 A 03/19/1986.
16 Q Thank you. Are you familiar with the person
17 by the name of Zenaida Gonzalez?
18 MR. GREENE: On behalf of Miss Anthony and
19 pursuant to the Fifth Amendment to the United States
20 Constitution and Article 1 of the Florida
21 Constitution, I instruct her not to answer that
22 question, and I object on the grounds it could tend
23 to incriminate.
24 MR. MORGAN: Chuck, she's going to have to
25 invoke that right herself, so I'm going to ask --1 MR. GREENE: No, she's not. I've just invoked
2 it.
3 MR. MORGAN: You don't believe she has to
4 answer that question herself?
5 MR. GREENE: No. I've just invoked it for
6 her. We're objecting on her behalf. The assertion
7 of the privilege is clear.
8 MR. MORGAN: So you're instructing her not to
9 answer that question? That you're answering it for
10 her?
11 MR. GREENE: No. I'm objecting on her behalf
12 and asserting her rights and privileges upon her
13 behalf and instructing her not to respond --
14 MR. MORGAN: And what is the --
15 MR. GREENE: -- because her response could
16 tend to incriminate her.
17 MR. MORGAN: And what is the basis for your
18 instruction?
19 MR. GREENE: Article 5 to the United States
20 Constitution and Article 1 to the Florida
21 Constitution.
22 MR. MORGAN: What is the factual basis for
23 that, sir?
24 MR. GREENE: I need not to explain our factual
25 basis other than to tell you that it could tend to 1 incriminate and provide a link in the chain of
2 evidence that could be used against her, and we're
3 not going to provide that to you.
4 MR. MORGAN: What pending criminal case are
5 you objecting in lieu of?
6 MR. GREENE: We made our objection and that's
7 all I'm going to state. We've made our objection
8 and that's all I'm going to do.
9 MR. MORGAN: Okay.
10 BY MR. MORGAN:
11 Q Miss Anthony, what do you understand the Fifth
12 Amendment applies to in this case? Your attorney has
13 invoked on your behalf your Fifth Amendment right. I
14 would like to ask you what is it that you understand the
15 Fifth Amendment applies to as to this case, Zenaida
16 Gonzalez versus Casey Anthony?
17 MR. GREENE: Objection, calls for a legal
18 conclusion. In addition, on behalf of Miss Anthony,
19 I assert her rights against self-incrimination
20 pursuant to Article 5 of the United States
21 Constitution and Article 1 of the Florida
22 Constitution, and I instruct her not to answer that
23 question on the grounds it could tend to
24 incriminate.
25 BY MR. MORGAN:1 Q Miss Anthony, you're aware that there is a
2 pending civil case against you of Zenaida Gonzalez versus
3 Casey Anthony. Are you aware of that, ma'am?
4 MR. GREENE: One moment, please, while we
5 discuss whether to assert a privilege.
6 (Off-the-record discussion was had.)
7 A Yes.
8 Q Are you aware --
9 MR. GREENE: Did you get her answer to the
10 last question?
11 MR. MORGAN: Yes. Thank you very much, Chuck.
12 BY MR. MORGAN:
13 Q What are -- what is your understanding as to
14 the allegations made against you in that civil matter?
15 MR. GREENE: Let me go off the record to
16 discuss whether we need to assert a privilege.
17 (Off-the-record discussion was had.)
18 MR. GREENE: On behalf of Miss Anthony, I
19 instruct her not to answer the question on the
20 grounds of attorney-client privilege because
21 everything she knows about the case was communicated
22 to her by her counsel.
23 In addition, pursuant to the Fifth Amendment
24 to the United States Constitution and Article 1 of
25 the Florida Constitution, we assert her rights 1 against self-incrimination and instruct her not to
2 answer and object to the question.
3 BY MR. MORGAN:
4 Q Miss Anthony, have you read the complaint
5 against you filed by our law firm?
6 MR. GREENE: You can answer that.
7 A Yes.
8 Q Now, based upon the complaint that you read,
9 what do you understand the allegations against you to be
10 in this civil matter?
11 MR. GREENE: One moment. We're going off the
12 record for a moment.
13 (Off-the-record discussion was had.)
14 MR. GREENE: I'm going to allow you to answer
15 the question except do not reveal anything that I've
16 communicated to you in the course of the
17 attorney-client relationship.
18 THE WITNESS: Okay.
19 A I'm aware that I'm being sued.
20 Q And are you aware of who you're being sued by?
21 MR. GREENE: You can answer that.
22 A An individual by the name of Zenaida Gonzalez.
23 Q Have you ever met Zenaida Gonzalez?
24 MR. GREENE: Just a moment, please.
25 (Off-the-record discussion was had.) 1 MR. GREENE: Objection. On behalf of Miss
2 Anthony, we assert her rights against
3 self-incrimination pursuant to the Florida
4 Constitution Article 1 and Article 5 of the United
5 States Constitution and instruct her not to answer.
6 BY MR. MORGAN:
7 Q Now, Miss Anthony, are you aware that our
8 client, Zenaida Gonzalez, was questioned by police
9 authorities in regards to the disappearance of your
10 daughter, Caylee Anthony?
11 MR. GREENE: Objection. I assert the
12 attorney-client privilege on behalf of Miss Anthony
13 and instruct her not to answer the question to the
14 extent anything she knows came from communications
15 from her counsel and also on behalf of the Fifth
16 Amendment to the United States Constitution and
17 Article 1 of the Florida Constitution assert her
18 privileges and instruct her not to answer.
19 MR. MORGAN: Thank you.
20 BY MR. MORGAN:
21 Q Miss Anthony, was there ever a person named
22 "Zanny" or "Zenaida" who was a nanny to your child,
23 Caylee Anthony?
24 MR. GREENE: Objection. On behalf of Miss
25 Anthony, I assert her privileges against
  








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