5th Request to State for Discovery (Feb 29, 2008)

Proof Of Bad Faith: Intentional Refusal To Turn Over Discovery‏
From: cam huegenot (cameocares@live.com)
Sent: Fri 2/29/08 10:44 AM
To: scnl300@dshs.wa.gov (scnl300@dshs.wa.gov); tomasc@atg.wa.gov (tomasc@atg.wa.gov)


Dear Marie,

This is copied to you and to the Attn. General who advised you to turn over the discovery. It has been a week since you said you were going to fax the discover you had, over to my attorney. I asked you to fax it to me. The Attn. General agreed you had to give me the discovery.

You purposefully refused to promptly turn over discovery, and the Attn. Gen. then claimed it was because redactions had to be made. It has been several days that you've had to do the redactions, and my guess, if you were going to fax the discovery over, is that the discovery is less than 30 pages long.

Yesterday when I was in town to see my son, you and another CPS worker told me that I could pick up the discovery if I missed my return bus home to Bellingham, and stayed for the discovery to be given to me that afternoon. I took my bus home even though I was promised I could pick discovery up yesterday afternoon.

Now, this morning, I am in Bellingham and sent an email and made a phone call at approximately 10:00 a.m., asking for the discovery to be faxed to me. I was told you didn't have it "ready" and that you had no idea when it would BE ready. You were rude and difficult and this is despite knowing the next court hearing is for 2 weeks away and that you and your department has purposefully delayed and not turned over discovery in a speedy manner.

No one is going to believe you didn't or couldn't have had this ready for me earlier and that you're not jerking me around. You have promised one thing, and gone back, and then tried to manipulate me to stay in Wenatchee with a promise of turning over discovery which has been refused me and intentionally delayed beyond a reasonable length of time.

Unless this discovery is 2 boxes worth of documents, no one will believe you have been acting in good faith, in your obligation to promptly turn over any and ALL discovery.