Update: Patsy Brumfield reports on Zach’s motion in the Sunday edition of NEMS360 – What may they say, if Zach Scruggs questions key players?
Skipping the legal argument of Zach’s Motion for Depositions (below in Scribd format) and going straight to what everyone has always wanted to know:
“The following states the name of each person whose deposition is requested, along with illustrative (but not exhaustive) information explaining the discoverable information that person is likely to provide. For the sake of brevity, each entry incorporates the knowledge stated for prior witnesses”.
Mr. Backstrom was a co-defendant in this case, who worked in the Scruggs Law Firm across the hall from the Petitioner. Mr. Backstrom has discoverable knowledge concerning the Scruggs Katrina Group and their assessment of the Jones case, whether Petitioner ever knew about an alleged bribery scheme or whether there was any such bribery scheme. This Court has previously suggested that Mr. Backstrom would surely have discussed a bribery scheme with Petitioner (see Petition, D.E. 303 at 33), and Mr. Backstrom will put such speculation to rest. Specifically, Mr. Backstrom can provide context to the November recording, testifying as to whether Petitioner was present during key moments. Mr. Backstrom is also a witness regarding the existence of certain alleged conversations and emails, about which Timothy Balducci has testified falsely.
Mr. Backstrom can also testify to whether Petitioner ever did anything to join the conspiracy, in support thereof, or to conceal the same, along with the state of mind of the Petitioner regarding Judge Lackey’s order compelling arbitration. Mr. Backstrom also has knowledge of exculpatory discussions he had with federal authorities concerning Petitioner both before and after he became a cooperating witness, as well as about the existence or absence of any documentation of such discussions, which should have been disclosed to Petitioner. Mr. Backstrom will also impeach testimony and representations previously given to this Court by both Government witnesses and the Government itself. Mr. Backstrom presently resides in Texas, outside the civil subpoena power of this Court, making a deposition the only practicable way to get his testimony for this Court…(citations omitted)
Mr. Scruggs was the primary defendant in this case, and has discoverable knowledge about the foregoing issues. Mr. Scruggs is also in the best position to testify about who created the alleged bribery scheme, when, and how, and most importantly, whether Petitioner was ever told about that alleged bribery scheme. In addition, Mr. Scruggs knows whether Petitioner was ever informed about the $40,000 and $10,000 payments to Mr. Balducci, or whether Petitioner was informed that the legal work assigned to Mr. Balducci on a Hurricane Katrina case was a mere sham, as the Government alleges, to provide cover for reimbursing the alleged bribery funds.
Mr. Scruggs can also testify to whether Petitioner ever did anything to join the conspiracy, in support thereof, or to conceal the same. This testimony will also serve to impeach testimony and representations previously given to this Court by both Government witnesses and the Government itself. Mr. Scruggs resides in a Federal Correctional Institution in Ashland, Kentucky, outside the civil subpoena power of this Court, making a deposition the only practicable way to get his testimony for this Court…(citations omitted)
Zach also seeks to depose Steven Patterson,Timothy Balducci, Judge Henry Lackey, William Delaney, Joseph Langston, Anthony Farese, Tom Dawson, Judge David Sanders, and Robert Norman – specifics below the jump. Continue reading “Zach Scruggs files the mother of all motions – Motion for Deposition of all Scruggs defendants and key players UPDATED”