Free Motion in Limine - District Court of Arizona - Arizona

Case 2:O3—cv—O1892—ROS Document 251-3 Filed O1/16/2007 Page1 0f3

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1 talk about the now and what's happening, what's going to
2 happen tomorrow for·Dakotah like, hey, I have to go to
3 this deposition, you know, make sure he's covered when he
4 -gets home from school, I think I'1l be there.
5 But he's getting big now, he can one day —~
6 -one hour is not going to kill him, he knows grandma is
7 going to be there. But if it's an extended period of
8 time, no, he'll have to make·arrangements. And usually
9 Mark is there after school anyway beeause of football
10 practice.
11 Q. You were aware in 1992 that Pamela Hickey filed a
12 Petition for Order of Protection against you?
13 A. Yeah, 1'm glad you brought that up. Like I said,
14 I try to remember as_much as I ean and I'm pretty good
15 about l0 years, but, God, this occurred in 1992, what year
16 is it today, 2004. Isn't that 12 years and did I not say
17 I try to remember things up to 10-years. A lot of things
18 were happening here at this time and Jack had filed —— I
19 don‘t know when he filed divorce, I don't oare, I don't
20 want to-know about the problems they had between them and
21 I*m that way. I just don't want to know, it's none of my
22 business.
23 -Q. Page 2 of`the Exhibit Number 3 under paragraph
24 number 5 ~-
25 A. Where are you talking about?
Case 2:03-cv-O18BEPBOSHEBUéd¥nént}%BBB9·KIFiIeU6@13"}6/2fH§77- 8EF!aQge 2 of 3

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1 Q. The second page of the exhibit numbered paragraph
2 5.
3 A. I see, 5, yes.
4 Q. —— it has in handwriting in_responss to the
5 question "the defendant has committed and/or may commit an
6 act.¤f `domestic violence' as more specifically described
7 as follows (state specific acts and dates}“ and then in
B handwriting it Says "threaten and intimidate, interfere
9 ‘with custody of child unlawfully.¤ Did I read that
10 correctly?
11 A. You read that correctly and I don't Iecall that.
12 I don't recall what I did or what I said} Like I said, I
13 used to take care of Sam, his mother was in school, but I
14 don't recall intimidating her or threatening her at all.
15 I know I*ve helped her a lot, you know, and I still —— I
15 love Pam because she's a very nice person to my grandson.
17 She's his mother and I love her for that.
18 Q. Was there an incident that happened at Camelback
19 High School in November‘of 2002, so about five months
2G after this incident, in which you sustained a bruise to
21 your left shoulder?
22. A. Yeah.
23- Q . And did you call police about that?
24 A. No, I reported it to the Principal what had
25 happened.
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Case 2:03-cv-01892-ROS

Document 251-3

Filed 01/16/2007

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Case 2:03-cv-01892-ROS

Document 251-3

Filed 01/16/2007

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Case 2:03-cv-01892-ROS

Document 251-3

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