For Casey Anthony
CHARLES M. GREENE, ESQUIRE (via videoconference)
Charles M. Greene, P.A.
28 East Washington Street
Orlando, Florida 32801

ANDREW J. CHMELIR, ESQUIRE (via videoconference)
Jacobson, McClean, Chmelir & Ferw
351 East State Road 434 — Suite A
Winter Springs, Florida 32708

For Zenaida Gonzalez
Morgan and Morgan, P.A.
20 North Orange Avenue — Suite 1600
Orlando, Florida 32801


Let the Dissecting Begin

Page 5 of 51

Thank you. Are you familiar with the person by the name of Zenaida Gonzalez?

On behalf of Miss Anthony and pursuant to the Fifth Amendment to the United States Constitution and Article 1 of the Florida Constitution, I instruct her not to answer that question, and I object on the grounds it could tend to incriminate.

MR. MORGAN: Chuck, she’s going to have to invoke that right herself, so I’m going to ask —

MR. GREENE: No, she’s not. I’ve just invoked it.


And so it begins, John Morgan needed Charles Greene to explain the 5th Amendment of the United States Constitution and Article 1 of the Florida Constitution! He wasn’t too happy about Casey’s attorney answering for her. He wanted Casey to take the 5th in her own voice which proves to me that he planned to have this video conference released in the press for fame and fortune in hopes of winning this case in the court of public opinion.
John Morgan should reflect on just how effective this worked out for Orange County in the first degree murder trial of Casey Anthony. Thankfully the presiding Judge Lisa Munyun of this civil matter denied Morgan & Morgan’s motion to have this video conference released to the media.

This is a typical response coming from Casey Anthony’s counsel said to be heard over 60 times

We object and assert Miss Anthony’s privileges against civil self-incrimination pursuant to the Fifth Amendment to the United States Constitution and Article 1 of the Florida Constitution and instruct her not to answer.



The Objections

Objection One

Mr Greene:  On behalf of Miss Anthony, we assert her privileges against self-incrimination pursuant to the Fifth Amendment to the United States Constitution and Article 1 to Florida Constitution and instruct her not to answer.

Objection Two

Mr. Greene: I assert the attorney-client privilege on behalf of Miss Anthony and instruct her not to answer the question to the extent anything she knows came from communications from her counsel.

Mr. Morgan: Thank you.


Casey Anthony took the 5th when asked…

Mr. Morgan:
Miss Anthony, was there ever a person named “Zanny” or “Zenaida” who was a nanny to your child Caylee Anthony?

Mr. Greene:

When asked this question, Mr. Greene objected, attorney-client privilege

MR. MORGAN: And you heard José Baez in his opening statement state that you had made up the story of Zenaida Gonzalez; isn’t that true?

MR. GREENE: Just a moment while we discuss whether to assert a privilege.
(Off-the-record discussion was had.)

It was decided by Casey’s counsel that this was an attorney-client privilege issue.

Mr. Green allowed Casey to answer in her own voice. She said yes. Mr. Morgan then asked, “Was he being truthful when he said that or was he lying to the court?
Mr. Greene quickly objected on two accounts, one this was a compound question, two, this fell under attorney-client privilege.
Obviously, Mr. Morgan was attempting to slander Jose Baez for defending his client. Everyone knows, including “Mr. John Morgan” that the opening statement does not have to be proven in court.

At this juncture, Mr. Morgan retreated, “All right, Let me – let me -”

Page 20 of 51
Mr. Morgan asked “And, Miss Anthony, you’re aware that Zenaida Gonzalez filled out an application to live at Sawgrass Apartments, are you not?”

How would Casey know this? ZG filled out an application supposedly on June 17, 2008, not on June 16th, the date Casey claimed she dropped off Caylee, unless of course Casey is psychic.
As we would expect, Charles Greene objected on Casey’s behalf, asserting the 5th Amendment.

Mr. Morgan posed the next question. “Miss Anthony, the application that Zenaida Gonzalez filled out at Sawgrass Apartments enabled you to know a lot about her personal life, did it not?

Is this what ZG’s attorneys are contending, that Casey somehow had access to this information and that’s how she knew the names of Zenaida’s daughters? I’m not able to follow this logic because, firstly, the guest card was dated the day after Casey claimed to visit Sawgrass Apts, secondly, the only way that Casey would have access to her information is if she knew someone who worked at the Sawgrass office. Does Casey know Amanda Macklin?

When Morgan asked this, “Miss Anthony, are you aware that the police knew specific things about Ms. Gonzalez, including her children, the type of car she had that only have been provided to them by you?
Mr. Greene objected to the question’s form asserting; calls for hearsay, assumes facts not in evidence and that cannot be proven. In addition, calls for attorney-client privilege and the 5th.
I seem to recall that the police were feeding Casey with information at this time.
Mr. Morgan follows up with “Miss Anthony, are you aware that Ms Gonzalez was kicked out of her apartment complex because of the false information you gave to the police?
It was always my understanding that ZG lived in a motel room, not an apartment. I hope Mr. Morgan has proof to back up this claim.
Mr. Morgan should also be able to prove that ZG lost her job because of this misunderstanding which shouldn’t be very hard to do. I’m sure the Judge would accept a notarized statement from ZG’s employer stating the reason for her dismissal.

Mr. Morgan then asked, ” Miss Anthony, are you aware that the result of your false information to the police that Ms Gonzalez received phone calls threatening to kill her children, her two little girls? Were you aware of that, Miss Anthony?”
This assertion begs the question; does Ms Gonzalez have proof of this allegation? Are there phone records and reports to law enforcement that this occurred?

On page 26 of 51
“Let’s talk a little bit about the description you gave to the police of Ms Gonzalez. Miss Anthony, could you describe for us today what the description of Zenaida Gonzalez was that you gave to the police?”

“Objection. The statements of Miss Anthony speak for themselves. In addition, we
object and assert Miss Anthony’s privileges against self-incrimination pursuant to the Fifth Amendment to the United States Constitution and Article 1 of the Florida Constitution and instruct her not to answer.”

In my unprofessional opinion, I was thinking the same because this information is easily found in documented transcripts from the murder trial. Why would Mr. Morgan want to ask a question that he already has the answer to unless he’s trying to invoke an answer from Casey in order to discriminate her if she were to give a different description. A simple error in the description would make Casey seem untruthful which is ridiculous because this is the reason for the civil suit so I’m sure this was his intention. Yes Mr. Morgan, we all know she’s a liar. Remember the jury found her guilty on 4 charges of lying to law enforcement.

On page 28 of 51
In the deposition Casey again exercised her right under the 5th Amendment and did not answer this question,
“Have you ever seen this person before?”
as he pointed to a picture of his client, Zenaida Gonzalez.

After this response, Mr. Morgan comes back with this question.

So, Miss Anthony, in fact that is the Zenaida Gonzalez you were referring to when you made the false statements to police, is it not?

MR. GREENE: Objection to the form, among other things, compound and argumentative.

Indicative of Mr. Morgan’s propensity to badger Casey Anthony as she did not say that this was the person she was referring to when she spoke with the police.

However, Mr. Morgan did quote Casey statement, “that girl down in Kissimee” which I found strange. I’m now left wondering if Casey has seen this woman before.  Mr. Greene quickly objected to the form, compound and improper predicate and again took 5th on behalf of his client.

Interesting Questions that went unanswered that MORGAN asked:

    • .Miss Anthony, isn’t it true that there was a time in this murder investigation that the police met with you and you had the opportunity to exonerate Zenaida Gonzalez if you had wanted to?
      • Miss Anthony, isn’t it true that behind closed doors with the police and outside the view of the media you had this opportunity but decided not to take this opportunity and exonerate our client, Zenaida Gonzalez?
      • Miss Anthony, after you saw a picture of Zenaida Gonzalez shown to you by police, you then spoke to your mother about that, did you not?
      • Miss Anthony, have you ever been to Jay Blanchard Park?
      • Miss Anthony, what does timer 55 mean?

On page 33 of 51
Mr. Morgan asked, “Miss Anthony, when you spoke to your mother, you told her, in fact, that that was Zenaida Gonzalez, didn’t you?” Obviously Mr. Morgan misuses the word “fact”. There are no documents that support this accusation that I’ve found.
He continues to elaborate on the issue with the next question, “Miss Anthony, when you spoke to your mother and told her that that was the nanny for Caylee Marie Anthony, you knew, Miss Anthony, that your mother was then going to go out and publish your false statements to the media, to the press and to the public, did you not?

Apparently, Mr. Morgan believes that this is the “money shot”. This is the point that he’s hoping will bring in the dough but in reality, Casey’s mother, Cindy Anthony has never reported to the media that this particular Zenaida Gonzalez was the nanny, although, it is a fact that there are several women living in Florida who are named Zenaida Gonzalez. The fact is, Casey did inform law enforcement that this Zenaida was not the person she left Caylee with at the Sawgrass Apartments. Had she not told them this, I’m sure the police would have pursued and investigated this Zenaida Gonzalez much more than they did. Remember this Zenaida Gonzalez was exonerated by Yuri Melich within 3 days. Once the police discovered that this ZG wasn’t a suspect, that’s when law enforcement went full force on Casey Anthony as the murderer. Just as most of us know now, law enforcement spent very little time looking for a live Caylee.
I’m almost certain that the smell of decomposition in the Casey’s car that was parked in the driveway of the Anthony home, told them that Caylee Anthony was deceased.

On page 43 of 51
Mr. Morgan asks, “Miss Anthony, do you consider yourself a good mother to Caylee Marie Anthony? Mr. Greene’s objection to this question was stellar. Not only did he object as it as being self-incriminating, he asserted the question was argumentative designed solely for harassment.
Mr. Greene used the same basis for objection when Mr. Morgan asked, “Did your daughter die as a result of drowning?” Not only was it outside the scope and not in form, it was designed solely for harassment, much like the entire deposition. Quite frankly, there were only a handful of questions posed to Casey Anthony that actually pertained to his client Zenaida Gonzalez inability to earn a living which I thought was the basis for her civil suit.

Mr. Morgan ironically ended the deposition on this note

“Miss Anthony, because we do plan to have motions before a court and because out motives here are not to harass you or to embarrass you or to turn this proceeding into a circus, I conclude and suspend – not end – I’m going to go ahead and suspend this deposition taken of you. I hope that you and your counsel understand that we did not ask questions that many people wished we did concerning your employment history then and now, where you live, where you stay. We did not do this – we did this, this deposition, in pursuit of truth and not in pursuit of sensation.

There were two words that struck me in his closing. The word “circus” because as we all know the George, Cindy and Lee Anthony depositions were in fact a hilarious, colossal, ridiculous circus and the word “people” and the word “sensation” in the same sentence is a Freudian slip because in reality that is precisely what Mr. Morgan wanted, a “sensational circus for the people.”
Unfortunately for Morgan & Morgan, the Judge squashed his big idea and decided that the video of Casey Anthony’s deposition was not necessary for public viewing.

Judge Lisa Munyon is one smart lady.


*Note: John Morgan filed an “Emergency Motion For Protective Order Regarding And Objection To Taking Deposition Of Plaintiff, Zenaida Gonzalez, Before Casey Anthony’s Deposition Is Completed” yesterday, November 7, 2011 to stop Casey Anthony’s attorney Charles Greene from deposing his client Zenaida Gonzalez claiming Casey Anthony refused to answer most of John Morgan’s questions. The Zenaida Gonzalez’s deposition is scheduled for November 22, 2011 @ 9:00 am.
*oops, In the motion, John Morgan misquoted the date of Casey Anthony’s deposition as November 8, 2011. The correct date of her deposition was October 8, 2011.
Apparently, even seasoned, experienced attorneys are not always perfect in writing motions to the court.

*Note: Casey Anthony denied speaking to her brother Lee Anthony within the last 6 months and she has not spoken with her parents George and Cindy Anthony since October 14, 2008.

*Note: Andrew Chmelir is co-counsel to Mr. Greene. He and Charles Greene were in the room with Casey Anthony during this deposition via video conference.

*Note: John Morgan was asking the questions, his law partners, Matthew Morgan and John Dill were also in the room during this deposition via video conference.

*Note: As to be expected, on November 4, 2011, Matthew Morgan filed a Motion to Compel Answers to Deposition Questions. No ruling as of this date, Monday, November 07, 2011.