Jerry and Patricia A. Dixon, et al - Page 106




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          intimidation during the remainder of the evidentiary hearing,               
          which, as described below, eventually led to a further                      
          evidentiary hearing held on August 18, 1997.                                
          C.   Mr. Bradt's June 12, 1996, Letter to Mr. Kersting                      
               Mr. Bradt first testified at the evidentiary hearing on                
          June 10, 1996.  Mr. Bradt testified that he had no direct                   
          knowledge that Mr. DeCastro passed Mr. Izen's trial strategy to             
          Mr. McWade, but that he suspected the same by virtue of                     
          Mr. McWade's opposition to Mr. Izen's efforts to introduce                  
          evidence concerning collection litigation through Mr. Moseley.              
          See supra pp. 135-136.                                                      
          Mr. Jones recalled Mr. Bradt to testify on June 14, 1996,                   
          for the purpose of rebutting testimony by Mr. O'Neill on the                
          propriety of the summons issued by respondent to Mr. Kersting in            
          1987.  During Mr. Sticht's examination of Mr. Bradt, Mr. Sticht             
          offered into evidence a one-page facsimile of a letter that Mr.             
          Bradt had sent Mr. Kersting in Hawaii at 10:15 a.m. on June 12,             
          1996, which apparently was then inadvertently forwarded by                  
          Mr. Kersting's secretary to Mr. Sticht's office in Los Angeles              
          at 10:52 a.m. on the same day.  Mr. Bradt's letter includes a               
          discussion of testimony presented by Mr. Sticht's witness,                  
          Ms. Fisher, on June 10 and 11, 1996, and testimony presented by             
          Mr. O'Neill.  Mr. Bradt's letter refers to a letter that                    
          Mr. Sticht wrote to Ms. Fisher.  Mr. Bradt's letter also includes           
          disparaging remarks regarding Mr. Sticht's trial strategy and               
          tactics.                                                                    

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