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APPENDIX
On January 5, 2001, Ms. Zusi spent 2 hours reviewing an
informal discovery request from Ms. Spaid. Of the 33 items
requested, 18 were already in Ms. Spaid’s possession, 11 were
related to frivolous arguments, 3 were related to the trusts, and
1 was incomprehensible. We order Ms. Spaid to reimburse
respondent for 1 hour of Ms. Zusi’s time, the amount we estimate
was the result of Ms. Spaid’s knowing and reckless advocacy of
frivolous issues.
On January 10, 2001, Ms. Zusi spent 3.5 hours preparing for
a conference with Ms. Spaid and petitioner. Ms. Zusi had
received documents indicating Ms. Spaid would be asserting
frivolous issues relating to the abusive trusts and prepared
information packets for Ms. Spaid and petitioner. Ms. Zusi also
had to respond to Ms. Spaid’s motion for continuance. Ms. Spaid
admitted she filed the motion because she had missed the
discovery deadline. Since the motion for continuance was the
result of Ms. Spaid’s negligence, we reduce the number of
reimbursable hours by 1 hour. We order Ms. Spaid to reimburse
respondent for 2.5 hours of Ms. Zusi’s time.
On January 11, Ms. Zusi and Ms. Moe met petitioner, Ms.
Spaid, and some of petitioner’s “witnesses”. During the meeting,
the parties held a conference call with the Court in which Ms.
Spaid raised the “Delpit” and “Scar” issues, and the Court warned
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