2012-03-20 Depo of McCool

DISCIPLINARY BOARD 0 THE
LOUISIANA' STATE BAR ASSOCIATION

IN RE:
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JOYCE NANINE MCCOOL *
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The sworn statement of
.ECFIVE
APR 2 t) 2012
CE NANINE
.....
MCCOOL, taken at the Office of Disciplinary
Counsel, 4000 South Sherwood F rest
Boulevard, Suite 607, Baton Ro ge,
Louisiana, beginning at 9:20 a ffi. on March
20, 2012.
Before Mark LaCour, .Certified
Stenomask Reporter, in and for the State of
Louisiana.
Sworn Statement of Joyce McCool
March rzo, 2012
2
APPEARANCE:S
FOR THE OFFICE OF COUNSEL:
OFFICE OF THE DISCIPLINARY COUNSEL
Attorneys at Law
4000 South Sherwood Forest Boulevard
Suite 607
Baton Louisiana
BY: DAMON MANNING, ESQ.
* * * * *
CON TEN T S
EXAMINATION OF JOYCE MCCOOL:
By Mr. Manning:
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Reporter's Page:
Certification:
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MARKED EXHIBITS:
ASSOCIATED REPORTERS, JNC.
Mark LaCour, C.C.R.
2QaS) 216-2036
PAGE:
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(None)
S W 0 R N
March 1:>0,2012
S TAT E E N T
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JOYCE NANINE MCCOOL
1772 Orleans Street
Mandeville, Louisiana 70448
HAVING BEEN DULY SV; ORN'
TESTIFIED AS FOLLOWS:
E X A MIN A TIC N
BY MR. MANNING:
Q. Good morning, Ms. McCool. 'My
name is Damon Manning and I am a'deputy
disciplinary counsel here for the Office
of Discipl.inary Counsel. I wa s assi'gned
to investigate a complaint the: t was filed
against you by Deborah Gambre 1, G-A-M-B-
who I understand is c judge in
Mississippi?
A. Yes, sir.
Q. Have you had a to record
in Mississippi?
A. Yes.
Q. For the record the file number
is 28469. I have some questions for you
about some activities in the Eocial media
arena which because of the nature of the
complaint I will tell you -- and we'll
ASSOCIATED REPORTERS, INC.
Mark LaCour, C.C.R.
. zqt5) 216-2036
Sworn Statement of Joyce McCool March 0, 2012
4
she remarried now?
A. Maurer.
A. Correct.
name now?
Is Ms. Maurer a client of Okay. Q.
A. Yes, she is.
Q And I k now - - and w =' 11 tal k
A. She is now, yes.
Q. That's M-A-U-R-E-R:
Q. And how does she saV her last
talk a little bit about things like
Twitter and stuff like that which before I
read some of that stuff I knew nothing
about. I'm still in the dark ages, but
I'm blissfully in the dark ages. So we're
going to talk about proceedincs that
involve a lady named Raven Boyd I believe
was her married name at least when she was
married to Michael Boyd but I think -- is
yours?
about two different There's
a Mississippi case and a case
which I think is an adoption matter?
A.. Correct. And j list for
clarification in the adoption matter I
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Mark LaCour, C.C.R.
216-2036
Sworn Statement of Joyce McCool March 2012
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actually represent her but I

consider them both clients has
Q. What's his name?
A. Dustin C.
Q. And you said you cohsider them
both clients and you actually represent
Dustin. Do you represent'Raven
individually or specifically any other
matter?
A. She has a personal injury case
that my firm is representing tut the other
attorney. -- I don't do a lot of p'ersonal
injury so I gave it to the other attorney
in my office.
Q. All right.
A. In the sense that Raven asks me
a lot of questions about the adoption
process and I have talked too her
extensively about custody mat ers in
Louisiana I consider her a client. But I
don't believe that I represent her in any
other case directly in Louisic na other
than through the adoption.
Q -'T h e pet i t ione r i nthe Lou i s i a n..a
matter would be Dustin?
ASSOCIATED REPORTERS, CNC.
Mark LaCour, C.C.R.
(225) 216-2036
223
Sworn Statement of Joyce McCool March 20. 2012
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A. Yes.
A. Yes.
A. That's correct.
Eliska is of counsel. She's a new
her Yeah, and she her A.
Q. All right. Before we get into
-A We 11 , s he's not - - she' s.
Q. Both minors?
Q. And you have a family law
A. 2000, October 6, 20CO.
right to be a party or to appec r in that
to some degree because of the l1ississippi
proceeding.
Q. Sure. Dustin as I understand it
is seeking to adopt the childr=n that were
born to Michael and Raven?
Q 0 kay . And it' s the t" w0 g i r Is,
right?
the case itself tell me what yE ar were you
admitted to practice law?
your practice and how it's set up.
practice primarily?
A. . P.rimarily.
Q. You said you have a partner or
an associate or something. Te. I me about
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ASSOCIATED REPORTERS,
Mark laCour, C.C.R.

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A. We do.
U-A-R-E-Z.
minor landlord-ten'ant issues.' I mean I do
Q. Do y'all share physical office
Okay. Q.
Q. To the extent I blew right by
experience doing personal so I
refer any personal injury I. get to
her because I don't do a lot of them.
Q. What is her name?
A . Eli s k a, E - L - I - S - K-11., J u are z, J-
A. And I do bankruptcy. I do some
attorney. I remember how difjicultit was
just coming out of law school so I try to
he I p her out. An d 5 he has a I p t 0 f
space together?
reason I became a lawyer and my emphasis
pretty much a general. practicE but the.
has always been family law.
it, state name and your Qffice
address for the record.
A. Sure. Full name is Joyce Nanine
McCool. My -- and I was actually licensed
linder my maiden name mo;Vt ut I chahg-ed
it with th'e bar. My address 1772
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216-2036
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Orleans Street, Mandeville, 70448.

Q. How long have you been at that
address?
A. A year and a half.
Q. Are you licensed in any other
states?
A. No.
Q. You're from Louisiana?
A . B0 r n' and r a i sed .
Q. Where did you go to high school
at?
A. I started at Franklin and
actually didn't graduate. I 1l ave aGED,
then I joined the military.-
Q. Wha t branch?
A. Coast Guard.
Q. Okay.
A I was i nthe mil ita r y act i v e
duty for four and a half years. I was in
the reserves until 2006. I was activated
for both of the Iraq altercations,
operation Desert Freedom and Storm.
I don't kno'w, they all run together. I
was a..c t u a 11 yon act i ve 9. \l t y. fer t h re e .
years in 2003 to 2006.
ASSOCIATED REpORTERS, (Ne.
Mark LaCour, C.C.R.
(225) 216-2036
2'26
Sworn Statement of Joyce McCool March '0, 2012
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Q.
A.
Q.
Well, thanks for your service.
Thank you.
You've -- you've been discharged
4 since or
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A.
Q.
A.
I resigned."
And went to law
Actually went to law school
8 before that. I went to law sClool while I
9 "was still in the reserves and the "Coast
10 Guard didn't pay for any of that. But I
11 went to law school. I started in '97,
12 yeah.
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Q ."
A.
Q.
Where did you law school?
LSD.
Well, on the
16 road that you've traveled. It sounds like
17 it's been rewarding and trying probably at
18 t i moe s a s well.
19 A. I've had -- I can't complain.
20 Li f e i s abo u t c hal 1 enge sand -
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Q. I'm not really here to hear your
anyway.
A. Exactly.
Q. Let's tal k" -a little bit first
about this Mississippi case. : t' s Michael
Mark LaCour, C.C.R.
29.,5) 216-2036
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1 Boyd versus Raven Boyd, now Maurer, and
. 2 it's in the Chancery Court in Marion
3 County, Mississippi. Wha.t I understand is
4 that the complainant .in this matter, Judge
5 Deborah Gambrell, i$ now presiding'in that
6 case but she took it over I gu=ss because
7 Judge James Thomas, Jr., the original
8 judge, passed away. Is that information
9 you.
10 A. Sounds familiar. I wouldn't
11 know that first hand but --
12 Q. And I guess my is
13 you're not licensed in Mississippi because
14 I've asked you if you were in any
15 other states. Are you in any involved
16 in the Mississippi case?
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A.
Q.
Not at all.
Not having haven t sought or
19 been admitted pro hac vice?
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A.
Q.
No.
Do you know who rep-esents Raven
22 i nthe Mis sis sippica s e ?
23 A. She had an attorney name,d Alex
'24 I-G-'-N-A-'T-I-E-'-V.. ,.. r 'think 'he says
25 She's currently dealing with an
Mark LaCour, C.C.R.
216-2036
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out of the district court?
don't know.
with her appeal.
to Mississippi counsel she has
in
Q. So the Mississippi case is now
attorney, Patricia Smith, who is an
Q. Okay.
A. It's on appeal. Obv-iously it's
a custody case so the degree that --
attorney in Mississippi who's helping.her
A. You know, I really -- honestly
I'm not that familiar with Mississippi
procedure and so I know that she's on
appeal. I mean -- and I speak with Pethee
(phonetic) and -- who's Patricia Smith,
and I talked with Raven extensively about
her appea'l in Mississippi but I don't -- I
Q. I guess my only question was
don't know Mississippi law, I don't
understand Mississippi law. ] refer Raven
one of those questions becaUSE I .honestly
since the complaint was filed, and I
haven't checked the status of the case
Mississippi based on your comments
about Patricia Smith represen_ing her on
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ASSOCIATED REPORTERS, fNC.

Mark laCour, C.C.R.
(225) 216-2036
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huge.
It's really long. I've not -- I've read
hearing, the portions that afjFect our
A. There was -- there VIas a trial,
I have it electrcnically
to review the Mississippi record?
itself have you ever had the a! portunity
appeal I was wondering maybe had there
been a hearing, had there been in a trial
hearing, whatever they call it in
and a ruling that they were ap):>ealing or
are they
remember exactly the date, and the ruling
from that hearing is what Rave 1 is
Q. Now from the Missis:: ippi record
A. I have the MississiJ;pi record.
I have not been able to review all of it.
Mississippi, in August of last year, can't
appealing.
that record.
adoption proceedings here becapse they're
portions of the transcript the
disturbing, but I -- and I can give you
assuming that Raven would not <bject to
that but, you know, r have it. I just
don't ha.ve" time to go through it. r t' s
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Mark C.C.R.
216-2036
Sworn Statement of Joyce McCool March 0,2012
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1 . Q. I un d e r s tand . I wa' 3 jus t
2 curious to know whether or not your client
3 had. either made that available to you or
4 whether you had been able to it
5 through the Mississippi court system.
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A.
Q.
She brought it to mp.
And you would have I
8 rulings?
9 A. I have the record tr at they gave
10 her for appeal. She i to me and
11 we scanned it for her.
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Q.
A.
I got you.
And so I have an electronic
14 version of it and then she has access to
15 that through Drop Box. I don'1 know if
16 you're familiar with Drop Box. I help
17 Raven a lot and I'm not going to
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Q.
A.
How do you know her?
She came into my office, gosh, I
20 wish I could remember the year It would
21 have been 2007. I think I just got back
22 from the military and -- it waE either
23 2007 or 2008. She came to me about this
24 cas.e. and I advised 'her that I didn't
25 practice Mississippi law and I helped her
Mark laCour, C.C.R.
(225) 216-2036
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1 -- gave her some information about how to
2 hire a Mississippi attorney. And then her
3 husband actually. her husband worked for
4 my husband. I think that's prpbably how
5 she came to me, and then I did some work
6 for her husband. And then she and then
7 she came back to me at some po nt in
8 crisis in the case in Mississirpi frantic.
9 And, you know, I kind of do a life
10 coaching in my office so I to help
11 her. But part of the reason I became so
12 involved with this case is of the
13 children. and the compelling story of these
14 kids and the concerns that I for these
15 kids.
16 Q. And let me just say -- state to
17 you on the record so that it de esn' t come
18 across as me being callous those
19 underlying allegations. They I hope you
20 u n d e r s tand don' t nee e 5 s a r i 1 Y h a v e a
21 b ear i n g 0 nthe que 5 t ion s t hat h a v e for
22 you.
23
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A. I do.
I can-'t and I'm not involve..d in
&
25 what those allegations are and whether
ASSOCIATED REPORTERS, INc.
Mark LaCour, C.C.R
2?i5) 216-2036
Sworn Statement of Joyce McCool March 20,2012 '
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1 there's truth in what should c r should not
2 have' happened as a result of those'
3 allegations either at the dis1 rict court'
4 or the appeal court or even througl?- law'
5 enforcement because I think I understand
6 at some point maybe that Raven had filed a
7 criminal complaint or maybe'trere was a
8 criminal preliminary against
9 this
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A.
Q.
A.
There was --
Michael Boyd?
in There was in
13 Mississippi. But I understanc that
14 entirely but, you know, entirE lyon the
15 record I have to tell you that a big
16 component of my involvement ir this case
17 is based upon my conviction and commitment
18 to children in general and these children
19 in particular.
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Q.
A.
These are young children, right?
Very young children. When I
22 first met Raven th'ey were four and two.
23 Q. There is, and it ca ne in as part
24 of the which is why
25 it, a n Aug u s t 1 3, 2 aa7 0 r d e r b r:r J u d g e
ASSOCIATED REPORTERS, ltNC.
Mark laCour, C.C.R.
(225) 216-2036
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Sworn Statement of Joyce McCool March 2p. 2012
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1 Thomas who was in the Mississippi case at
2 the time
3 A. What was the date aqain, was it
4 August --
5 Q. August 13, 2007.
6 A. Okay.
7 Q. And it had something to do with
8 a motion, a petition that was brought by
9 John Smallwood who was guardicn ad litem.
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A.
Q.
Uh-huh.
And he was seeking temporary
12 emergency relief. And in looking at that
13 order -- I'm going to kind of Dust read a
14 couple of things I extracted f rom the
15 order and we'll talk a little bit about
16 -that as well, but the order says -- it
17 contains the statement, quote after
18 having been informed that the defendant,
19 who would have been Raven in the
20 Mis sis sippica s e , s a aft e r h a 7" i n g bee n
21 info rmed tha t the de f endant d ~ e s not
22 oppose the petition the court finds that
23 the motion is well taken and should be and
24 is here-by granted. Then further -down it
~ says Raven Boyd, Wanda Phillips, -- I'm
Mark LaCour, C.C.R. -
2 ~ 4 5 216-2036
Sworn Statement of Joyce McCool March' 0,2012
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1 going to stop. Who is Wanda
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A.
Q.
A.
Q.
Raven's m,other.
Okay.
Quite a fire
So the order says Raven Boyd,
G Wanda Phillips and any persons acting on
7 their behalf or at their direction are
8 hereby enjoined from making the same or
9 similar allegations of sexual abuse as to
10 the minor children of the parties herein
11 and then it also says Raven Boyd, Wanda
12 Phillips and any person acting on their
13 behalf or at the'ir direction are enjoined
14 from subjecting the minor children to
15 anymore mec:iical examinations j or the same
iGor similar allegations of sexual abuse.
17 Okay, again that date was August 13
th
of
18 2007. Do you know from -- I dcn't want to
19 get into attorney-client privj lege, okay,
W so do you know from having reviewed the
21 record or since you don't represent her in
22 Mississippi maybe having disct ssed the
23 Mississippi case did this -- would this
M have been after there been
25 some type of criminal investigation or an
ASSOCIATED REPORTERS, lNC.
Mark LaCC?ur, C.C.R.
(225) 216-2036
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1 by the child welfare
2 services in Mississippi of these
3 allegations? I'm wondering what prompted
4 this order because it's pretty specific.
5 A. Well, I co u 1 don1 y v e you
6 speculation on what prompted that order,
7 and as far as What was go i n g 0 inAu gus t
8 of 2007 I know that -- I'm not sure what
9 prompted the order and I would be guessing
10 to say what. I know that he We s
11 ultimately, Mr. Michael Boyd, was
12 ultimately indicted in 2008.
13 Q. What happened with
14 indictment?
15 A. It was dismissed a year
16 and a half.
I twa s dis miss e d a s t J u n e 0 f
17 -- I don't know. It was about a year and
18 a half later they dismissed it.
19 Q. The indictment dealt with these
20 a 11ega t ions 0 r
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22
A.
Q.
Yes.
-- similar allegatibns of sexual
23 abuse?
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:A.
Q. Okay. There is there is
Mark LaCour, C.C.R.
216-2036
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1 later a Jupe 2008 order and that is
2 probably also by Judge Thomas, but
3 nevertheless it says based the nature
4 of allegations made and pleadjngs in
5 this matter and to protect the minor
6 children in this matter the entire file
7 shall be sealed by the law clerk and not
8 made available to any person until further
9 order of this court with notice of any
10 such request for disclosure being given to
11 both parties and the court appointed
12 guardian ad litem herein. Okay. So
13 t hat' s J un e 0 f 2 0 0 8 . and t hat was b e for e
14 Judge Gambrell got involved ir the case.
15 Is that a fact, the fact of of the
16 record? Is that something that you would
17 have known about?
18 A. I'm aware that the tecord was
19 sealed. I mean I heard that
20 Q . Do you k now when y 0 11 W0 u 1 d h a v e
21 come to know t ha tinforma t i on
22 A. I don' t . I'm - - 1,,17 e bee n a war e
23 of it for a while so it's -- I don't know
24 that I would have of it in June
25 2008. Is that what you said?
Mark LaCour, C.C.R.
2cg2{S) 216-2036
Sworn Statement of Joyce McCool March '0,2012
20
to I d me.
not be so unusual to seal a record of
these kind of a 11 ega t ion s d e a i n g with
minor children, is that right in your
It happens all the time. Right.
Q. Yes.
A.
Q. My understand is that it might
A. ButI'm sure I became aware of
A. It would have been because Raven
it, you know, more than a year ago.
Before her compiaint was made I'm sure I
was made aware that the recorc was sealed.
Q. Would you have, if lYou know,
first become of it through yOl r client
telling you about it or h your
reiew of the record?
experience?
I actually ask to seal the records here
often.
Q. Let's switch gears just a little
bit and talk about the Louisicna
proceedings, the adoption pro8eedings
which are in the 22
nd
Judicial District
Court before Judge Dawn Tell me
how that came about and how yeu got
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Q. Yes.
Dustin, Raven's husband, has aised these
consents and the court can igrore any
have -- you know, the money was an issue.
So it took them a
I don't know if you
So based on those facts
involved in that case.
A. Well, under Louisiana law if you
A. In the adoption proceeding?
if a parent doesn't pay court ordered
child support or makes no onable
efforts to maintain contactw th their
k 11'0 w t his .
objection made by a non-compl ant parent
children for six months a stef-parent can
file to adopt and petition to adopt his
step-children as long as the n other
who is not paying.
girls, supported these girls. The girls
know him as Dad and he wanted to adopt
them, so we filed the petitior to adopt.
It took them a little while. They didn't
Raven wasn't receiving child :support so
they were struggling.
while to come up with the money even
t_h.ough I'd given them .a break of fees but -.
they had to come up with filing fees and
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2 Q. She and her children had
3 relocated to Louisiana or mOVE d to
4 Louisiana?
5
A. '
Oh yeah. They live in
6 LGuisiana -- well, they were living in
7 Louisiana when I first met Raven.
8
9 A.
Okay.
I'In not sure when s 1e moved from
10 Mississippi. I know it had to
11 do with the proceeding but I think it
12 actually had something to do with what set
13 all this into motion but she's lived in
14 Louisiana for years.
15 Q. The Lou i 's'i a n a ado p t ion
16 proceeding, is that record sealed also?
17
18

Q.
Yes, I bel i eve i t i
Do you know when it was sealed
19 and why it was sealed?
20 A. I'm trying to if I -- I
21 think I asked to seal the reco cd when we
22 brought the last emergency ex p.arte
23 petition but,. you know, I might have I
.24- -don't know if we adopt - - you } now, I
25 don't think the adoption proceeding is
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1 sealed.. I think the emergenc 1 proceedings
2 were sealed because there was some, you
3 know, the girls writings and drawings were
4 in the record ..
5 Q. So the adoption
6 if I understand some
7 evidence carne to you that you felt
8 compelled to bring an emergen -:.y or request
9 an emergency hearing?
10 A. Right, but that was -- it
11 actually was brought in a sepc rate hearing
12 in the adoption proceeding.
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Q ..
A.
Q.
A ..
Q.
Okay.
The adoption is
So there's a third matter?
Third as in Louisiana?
The Mississippi anc the
18 Louisiana adoption and then tl e third one
19 being a Louisiana emergency p oceeding.
20 Tell meab 0 u t t hat b e c a use I' n not .a war e
21 0 fit.
22 A. The -- bringing the emergency
23 proceeding would have been in the summer .
. 24 Should I have.. brought the file? It. was iIi"
25 the summer. It was bas.ed on made
ASSOCIATED REPORTERS, (NC.
Mark LaCour, C.C.R.
216-2036
Sworn Statement of Joyce McCool March ~ 0, 2012
24
1 by the oldest girl who is now line 'who had
2 just been ordered back to see her father
3 unsupervised in the house where she claims
4 extensive sexual abuse went on. In
5 response to that she made a bU1ch of
6 drawings that were very explicit detailing
7 the level.-- the type of abuse Raven
8 .came to me because she had tri ~ d to have
9 the.Mississippi court review that evidence
10 and she was unsuccessful so we asked the
11 Louisiana court to exercise emergency
12 jurisdiction under the UCCJEA based on the
13 harm that we believed --
14 Q. That was before the adoption
15 proceeding started?
16 A. No, that was while t he adoption
17 proceeding was -- actually has been put on
18 indefinite hold. by ~ u d g e Amacker and -- in
19 which I'm about to file a motion in that
~ proceeding if that matters but
21 Q. Adoption proceeding in Louisiana
22 stayed by Judge Amacker?
23
24
A.
Q.
Uh-huh.
Thisother issue corles up wh'ere
25 you -- new evidence or the inf()rmation
Mark LaCour, C.C.R.
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Sworn statement of Joyce McCool March O. 2012
25
1 that compels you to now bring it back
2 before the Louisiana court --
3
.4
5
6
Q.
A.
Q.
Correct.
-- and you do so?
Yes.
My question to you s was it.
7 brought under the same docket number as
8 the adoption proceeding? Was it brought
9 as a completely separate proceeding?
10 A. I think they made it -- I think
11 they I can't -- when you bri ng it in
12 you let the clerk of court dec ""de on these
13 type I ' vel ear ned to let t h m dec ide do
14 they want to assign -- give it to the same
15 proceeding or do they want to qive it a
16 new number. I could probably ind out for
17 you real quick if I can pull ut: my I
18 don't have internet access.
19
20
21
Q.
A.
Q.
You can let me know later on.
Okay.
I'd be interested tc .know that.
22 So you filed it to be handled either way,
23 either as a completely new mat or to be
"24 j oi.ned in:wi-th ,the.,ado-ption' pr'(Dc'eeding but ..
then that would have. presented the hurdle
Mark LaCour, C.C.R.
216-2036
26
of the UCCJEA.
was filed?
when, about when?
'Q. Okay.
I maDe that they were the same case.
since it was a new -- I want to say that
it was brought under a separate'number but
in fact I think I proceeded assuming that
of that matter being stayed, right?
A. Oh no, I didn't see it that way
A. August of 2011.
Q.. Okay .. W.ha..t once that
Q. Got you ..And that vas filed
A. It was entirely based on asking
mistake actually procedurally in the
appeal but the case -- all I tell you
is I think that it was filed u1der a
with the adoption really.
separate number and it had nothing to do
the court to exercise its emergency
j uri s die t ion for chi 1 d c u s t 0 d rat her t han
adoption where Louisiana clearly has
jurisdiction. Louisiana woule n
r
t have
jurisdiction on custody under any other
fact except under the emergency provisions
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1 A. We had an emergency hearing in
2 front of Judge Amacker. Judge Amacker
3 denied the motion. I took an =mergency
4 writ to the First Circuit. The First
5 Circuit denied it and then I took writs to
6 the Supreme Court who also denied my writ
7 application.
8 Q. And so you're back With the
9 adoption proceedings which arE still
10 stayed as I understand inLouisiana, okay.
11 So there's nothing active or ongoing in
12 t h ~ Louisiana proceedings todc y?
13
14
A.
Q.
No.
And they will remaifl that way I
15 guess until the appeal in Mississippi is
16 resolved?
17 A. No, I'm about to fi e a motion
18 in the adoption proceeding.
19
20
Q.
A.
Okay.
Yes.
To get it restarted?
21 Q. All right. You just said that a
22 minute ago.
23
24
A.
Q.
I did but I --
It' ~ s .- C 0 h f u s i Ii-g . Tr 1 s t me. . You
25 know way more about family law than I will
Mark laCour, C.C.R.
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28
1 ever know so I appreciate you educating me
2 along the way here. All right. There was
3 at some point an petit jon?
4
5
A.
Q.
Yes.
And it was on dot org or
6
7
8
9
10
maybe some other website as WE II?
A. I think there was a ctually two.
Q. Tell me about these online
petitions .. First, whose idea"
A. I'm so sorry. It
i"
sort of a
11 brainstorming session with me Raven, some
12 other people .who are concernec about
13 children and, you know, I have an
14 extensive network of people wto, don't
15 parti'cularly care about the We y children
16 are tre.ated in the court system. And we
17 were really concerned about these kids.
18 So it was a group brainstorming session'
19 but I participated in it. I w(ft s the r e .
20 Q. Sur e' . When' did t h a.. kind 0 f
21 take place? When was the braihstorming
22 and developmental phase of this?
23 A. It would have been the
24 point. that- .Judge Gambrell issued an ex
25 parte order. The order that she issued to
Mark laCour, C.C.R.
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Sworn Statement of Joyce McCool March 2P. 2012
29
and
molested took place in chambers off the
the reason is when a parent dOEsn't
that date which was in July, then
Because
Q. July of what year?
A. Of 2011. And then within two
order the children back to unsupervised
visitation at the place where they were
record. And I mean that's my
understanding and based on what's in the
record that's what But and
it would have been from-that point, from
weeks of date I would say
there were some efforts made
Mississippi to prevent the from
having to go and those were not, you know,
they weren't effective. So th next
question was what else, what could be
done to protect the children.
Q. Let me kind of ask a question
that's a little off the path hE re just so
that I can try to stay up on family law
and what's going on between LOlisiana and
Mississippi. You said that thp' Louisiana
pr"ocee.d.ings were being b.rought and part of
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Sworn Statement of Joyce McCool March :>0,2012
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. exercise their parental right 3 of

visitation or custody or live up to their
obligations of support for si] months then
they give up those rights or step-
parent can then move to adopt and take
over those parental rights?
A.' Right. And I think really the
key here, it's not that they give up
rights. It's just that the when
faced with someone saying I want to adopt
this child can ignore the of a
parent who has not either paid support,
court ordered support for six nonths or
has failed to make a reasonable effort to
maintain a relationship with the child.
So it's not like they're not a parent or
they can't say anything. They can object
but the court is no longer obI .. gated to --
Q. that point:>
A . - - con's ide r the i rot j e c t ion.
Q. Okay. And -- but then I'm
seeing here in July of 2011 dOES it look
like that the father was still through the
c.U r t s ys t--e m trying .. toen for c e tho s.e
rights to visitation and/or cU3tody?
Mark LaCour, C.C.R.
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31
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2
3
4
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A.
Q.
A.
Q.
A.
Mike Boyd?
Yes.
Was he trying to enforce?
Yes.
Well, on paper it w)uld seem
6 that way but the caveat there ~ s that it
7 doesn't matter if a parent once served
8 with a petition for adoption then suddenly
9 r.e-invests themselves in the j;:rocess and
10 tries to cure it. All that rna footers is
11 that that six month period occurred and
12 that's what establishes the --
13 Q. Matters is what has already
14 happened from the filing of the petition,
15 not what happens going forward?
16
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21 ru 1 e .
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A.
Q.
A.
Q.
A.
Q.
A.
Yes.
I understand.
Eventually.
I got you.
It's not a real black and white
I understand. N o t h ~ ng is.
Right.
All.right. Who prepared ':-.- and
25 I k now the r e 'was n ' t I ike a p h Y~ i c a I
ASSOCIATED REPORTERS, nN"c.
Mark LaCour, C.C.R.
(225) 216-2036
~
March '0,2012
32
1 petition that y' all then scanr ed and put
2 online but there's some, you know,
3 something had to be set up.
4 A. Oh, right. It was typed out.
5 We did it together. We sat do vn.
6
7
Q.
A.
At your office?
It was either at my' office or at
8 my house.
9 Q. How do you go about uploading or
10 creating links to this?
11 A. Oh, it's all done at tomatically.
12 It's actually
13 Q. Is it what that webE ite is
14 designed to do?
15
16 do.
A. Exactly what it's dE signed to
17 Q. Who is change dot org?
18 A. Some non-profit -- ] think
19 they're a non-profit agency which
. 20 bel i eve s t hat, you k now, inch c ~ n get h r 0 ugh
21 social activity and encourages people to,
22 you know, get involved and --
23 Q. What about Bridge tc Justice?
U What is that?
25 A. That is a non-profit
ASSOCIATED REPORTERS, I l ~
Mark LaCour, C.C.R.
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Sworn Statement of Joyce McCool March. 0, 2012
33
1 organization that we probably will try to
2 get off the grouhd in the next six months.
3
4
5
Q.
I
A.
Q.
Something you're involved in?
Yes, absolutely.
Is it your brainchild?
6 A. It is my, yes. I t ~ my what
7 I want to do with my training ~ n d my
8 skills, absolutely ..
9 Q. And this Bridge to l ustice was
10 used to help facilitate the online
11 petition?
12 A. It may have been -- we used it
13 as for the website and the E mail, you
14 know, because of the potential for, you
15 know, just trying to keep everything
16 separate. I already get too mlch email at
17 my office so -- and to allow Rc ven access
18 to any email. I couldn't give her access
19 to my office email so we set ut:, you know,
20 i twa s jus t - - i twa sal rea d y the res 0 we
21 use d t hat a sac0 n v e n i en c e t h i ng .
22 Q. And you don't know VI ho operates
23 the web sit e, Chan g e dot 0 r g ? Hhot h e --
24
25
.. A.
Q.
I don't know.
There's technical wJrds for
Mark LaCour, C.C.R.
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251
March 2P. 2012
34
and
A. No.
word.
one we used.
It's -- It's not who operates
A. Who owns it?
Q. . -- ISP or whoever tr e
that.
A. And I have to tell-ybu honestly
A. Okay, the re you go. Tha t' s the
A. Yeah. I think there was another
them to facilitate?
Q. Administrator.
that you're involved in other han you use
Q. -- organization or omething
A. Who owns it? No, but you -- all
you do is just go online to Chcnge dot org
Q. Unlike Bridge to Change
dot org is not your --
I am not exactly sure what her complaint
Q. That is the word. s stop
for a minute and physically tale a look at
some of the stuff in the petition because
now we're kind of getting to tte meat of
what the judge was complaining about in
her complaint to this office.
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35
1 is except that she made some very serious
2 allegations against me regardj ng
3 intimidation of a federal -- of a state
4 j u d g e . But 0 the r t han t hat I. not --
5 I'm not sure what her complaint against me
6 is.
7 Q. Let me look. I gnorj ng the
8 highlights which obviously I put on there
9 for me, just flip through real quick and
10 tell me if that is a copy of the online
11 petition that y'all created there and set
12 up on that Change dot org webs teo
13
14
A 0"
Q.
It looks very much like it.
Ok a y . An d it's s eve r alpage s
15 and let me ask you a couple of things.
16 One says it's talking about these minor
17 children of Raven and Michael?
18
19
A.
Q.
Yes.
And it says listen to their
first disclosure to Raven and has a
21 1 ink wh i chI ink s t 0 a n a u d i 0 0 j the
22 children speaking to someone W:10 I presume
23 to be Raven, their mother?
"24
25
A.
Q.
That's . co- r r e ct .
Okay. And then it and a
Mark LaCour, C.C.R.
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253
March 2( 2012
36
1
day later their second and the il there's a
2 second link to another audio 0'" kind of
3 she wasn't interviewing her children but,
4 you know, I mean she was
5 A. Right.
6 Q. engaged in a Q and A about
7 some of these very sensitive issues and
8 allegations. Where did the -- where did
9 these come from? Where did thE=se audio
10 recordings of the mother and these
11 children come from?
12 A. She -- it was on a cell phone.
13 She had recorded it on her cel ~ phone.
14
15
Q.
A.
When?
At the time -- you n ean when was
16 the date?
17 Q. Yeah. Wha t time frdme in the
18 proceedings was this taking place?
19 A. Oh, i twa s be for e t ~ e
20 pro c e e din g sst art e d .
21 Q. Was this part of th = emergency
22 proceeding in Louisiana? Did it predate
23 the emergency proceedings?
24
A. It wasn't ~ it was after the
25 divorce in Mississippi betwee.ll Michael and
Mark laCour, C.C.R.
(225) 216-2036
2'54
37
Raven I did file and all the ilitial,
everything had essentially beEn resolved
and before any allegation of sexual abuse
were brought. I think they wep:e divorced
in 2006 and I think she brought her
allegations of sexual abuse in January of
2007, January or February of 2007.
Q. Those were made a p 3.rt of the
Mississippi proceedings also, the
allegations of abuse?
A. I'm pretty sure. and I'm
only answering that because it's a
technical to some degree. Was it
actually made a part of the record? I
know that she repeatedly triec to bring
those allegations to the Mississippi court
and she was fairly unsuccessft: 1 even to
date.
Q. Do you know if actu3.l copies of
these recordings were offered"into
evidence in Mississippi?
A. According to Raven those
recordings were never offered into
e vi den ce_.
Q. This says, this is the online
Mark LaCour, C.C.R.
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255
Sworn statement of Joyce McCool March 0,2012
38
1 petition, it says after the links
2 to the two records it says now consider
3 that no judge has ever heard these
4 recordings. Why? Because for four point
5 five years they have simply refused to do
6 so. On August 16, 2011 Judge Deborah
7 Gambrell and the Chancery CaUl t of Marion
8 County, Mississippi once again refused to
9 admit all of Raven's evidence including
10 these recordings. Maybe that answers the
11 questions. At least based on that it
12 would suggest that she offeree them but
13 they were not admi tted.
14 A. And at the time that that was
15 written I think based on Raven's
16 understanding what meant to oj fer
17 evidence, that was what she believed. In
18 reading the transcript. it sour ds like the
19 evidence that she did have ana offered at
20 t hat h ear i n g wh i c h was n 't the ere cor ding s
21 wasn't admitted but -- or it was and then
n it 'was thrown out, but she didn't --
23 a'ctually her attorney did not bring any of
24 ev-idence to that hearing 50 it ...
25 wa 5 n 't eve n 0 f fer edt hen .
Mark LaCour, C.C.R.
(225) 216-2036
2'56
39
1 Q. Oka.y. And right just so I'm
2 c I ear I' m 0 n 1 y talkingab0 u t "t he seau d i 0
3 recordings.
4 A. They were not at the hearing.
5 At the time Raven believed that offering
6 it into evidence meant other
7 than the technical term and sc that's why
8 it said that it was offered. But in fact
9 it wasn't even brought to court that day.
10 Q. So to your knowledge the two
11 recordings that are linked on the petition
12 website or even for your Twitter account
13 are not in the Mississippi record?
14 A. That's to my knowledge. And
15 because the record is sealed there's no
16 way for me to know if they're actually in
17 there but according to Raven, no, she
18 never
19 Q. You said you have a copy of the
W record though.
21
22
A. Well, but even in a copy of the
even a copy of the record that was
23 submitted to the Supreme Cour Raven has
24 been de-nied access to any of the exhibits
25 that are made part of the file .. So she
Mark LaCour, C.C.R..
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2'57
Sworn statement of Joyce McCool March :>0,2012
40
1 can't even tell what's in ther e and so of
2 course if she doesn't know I don't know .
.. 3 But she was adamant that she -- that that
4 was -- that most of this evidence was
5 made part of the record.which is
6 part of her frustration.
7
8
Q.
A.
Okay.
And based on what I can see the
9 only evidence that was ever ac tually
10 presented -- and, you know, I can't access
11 the !ecords so and it' s sippi. But
12 based on what I have seen the only
13 evidence that was ever offered of the
14 abuse -- the only time it was ever
15 directly addressed was in of 2011.
16 And what was offered was the drawings that
17 Harley made, and at the first the court
18 admitted them and then the COl rt said she
19 wasn't going to admit them.
20 Q. Well, then explain the statement
21 tome t hat we jus t read bee a use itsa y s
22 ve r y mat t e r 0 f f act, 0 n Au gus t 1 6, 2 0 11
23 Judge Deborah Gambrell in the Chancery
24 'Co'urt of Marion County, Missi 3sippi" once
25 again refused to admit all of Raven's
ASSOCIATED REPORTERS, tINe.
Mark LaCour, C.C.R.
(225) 216-2036
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41

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evidence including these recoldings.
A. She -- that was RaVE n' slay
understanding of what it meant to offer
evidence but she did offer evidence at
that hearing and the court refused to
consider it. And she --
Q. But not these recorjings?
A. Not those recordings.
Q. SO a reading or an
interpretation of that stateme nt that
would suggest that Judge Gambrell refused
to admit or consider these recordings.
That wouldn't be true because they' were
never formally offered?
A. Well, in the formal sense it
wouldn't be true. What actually did
happen was Raven told the court that she
had evidence that she wanted to present to
the court of the abuse and the court would
not even entertain it. And then
apparently Raven -- what came out to me
afterwards was that the eviden.ce wasn't
even in court. I mean her attorney didn't
eve n b r i n gall her e v"i den c e . S"h e was'-
incensed that he had not even brought it.
Mark LaCour, C.C.R.
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Sworn Statement of Joyce McCool March ~ O. 2012
42
1 But from her perspective she had asked the
2 court to look at -- she has lots of
3 evidence and the court would not look at
4 it, wouldn't even entertain it. The
5 evidence that she did bring to court,
6 laughed at her, and through it out.
7 Q. The -- did you have a copy of
8 the Mississippi record before creating the
9 online petiti'on?
10 A. No. I actually just got a copy
11 of the record about two weeks ago.
12 Q. The recordings, the two that
13 we' ret a I kin gab0 u t, 0 n I y tho ~ e two and I
14 understand maybe there is more and
15 obviously there's more e v i d e n ~ e that y' all
16 had and that y' all are trying to bring,
17 but focusing on the two recorc ings right
18 now was that something that became a part
19 of your efforts in that emergency
20 proceeding brought in Louisiala before
21 Judge Amacker?
22 A. At the -- we would ~ v e brought
23 them had we been given an evidentiary
24 hearing., We were,not .q.llowed an
25 evidentiary hearing. All we 1: rought at
ASSOCIATED REPORTERS, me.
Mark LaCour, C.C.R.
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Sworn Statement of Joyce McCool March 2 >, 2012
43
I .
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the ex parte hearing was the of the
book.
Q. The journal?
A. The journal.
Q. But not the recordi 19S?
A. No, because, you kn<pw, it was an
ex parte hearing.
. Q.
And that's why I wondering
9 if the recordings had ever been formally
10 offered or. formally presented into the
11 record of the Louisiana proceeding. before
12 Judge Amacker.
13 A. No, but we would tainly like
14 a platform to be able to do with.
15 Q. Well, I understand. I want to
16 I'm just trying to clarify whether that
17 has in fact been done as we si f- here
18 today.
19
20
21
A.
Q.
A.
Right, no, it hasn't.
Okay.
But not because of of
"22 e f fo rt .
23 Q. I understand. And the online
24 petition then.. talks__ about -Jude e Amacker.
25 It says Judge Dawn Amacker in the 22
nd
Mark LaCour, C.C.R.
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Judicial District Court for the Parish of

St. in Louisiana is also refusing
to hear any evidence or to protect -- and
it lists the two minors's names even
.though the law requires her tc have a
hearing and to take evidence.
A. It does.
Q. And this is a reference to the
fact y'all were given an ex parte hearing
and not an evidentiary hearinq where you
could present that evidence? Is that a
fair
A. Correct.
Q. -- interpretation?
A. Correct.
Q. Okay. Then the bottom
of this page it says sign our petition
telling the judges that there can be no
justice for, and it lists the children's
names again, or any child if the law and
e v ide n c e i s i g nor e d . Tell t h m the y mus t
look at the evidence before t ley make a
decision that will affect the rest of, the
children} s nam_es,lives . Ask-yourself
what if these were your daugh_ers. Who
Mark LaCour, C.C.R.
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March 2P, 2012 45
A. Raven.
A. Yes.
A. Correct.
Raven?
I t
It says read the
Q. Now it also says thtis, Ms.
A. Exactly.
Q. -- same issue, right?
Me CCi 0 1 . " says ,.. itas k s t h que s t ion
Horrified?, question mark, ca 1 the judges
Q. Okay. And that was where you
were telling me the first Circuit and the
Louisiana Supreme Court denieca writs?
Q I twou 1 d h a v e bee n' n b e hal f 0 f
Q. And then there's some more and
That's that --
I'll take ownership of it.
remember exactly.
it says want to see more go to and it
writ submitted to the Louisian a Supreme
Cour t on. Aug us t 12, 2 011 . Th a It was a wr i t
that you filed on 'behalf of Rawen or on
behalf of her --
links another website.
crafted that paragraph?
A. You know it was prolbably me.
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ASSOCIATED REPORTERS, [Ne.
Mark LaCour, C.C.R.
216-2036
Sworn Statement of Joyce McCool March 0.2012
46
1 and let them know. And then it goes on to
2 list Judge Deborah Gambrell, Chancery
3 Court, Marion County, It
4 gives her phone number, her fax number and
5 her email address. And then it lists Dawn
6 Amacker, Judge, 22
nd
JDC, St. Tammany
7 Parish, Louisiana. It lists a website.
8 It. lists a phone number for Amber
9 Mitchell, Staff Attorney, and a phone
10 number and fax line for Michel Ie Simon,
11 secretary to Judge Amacker. Pnd it also
12 lists the phone number for the Louisiana
13 Supreme Court. Whose idea?
14
15
A.
Q.
Probably mine.
Why would you, and on what
16 auth.ority would you encourage individuals
17 to contact these judges direc ly and voice
18 their position, displeasure or agreement
19 with how the judge was handlir g or ruling
20 i nthe s e pending cas e s ?
21
22
A.
Q.
Why --
Yeah. Why did you that?
23 What was the rationale or the reasoning.
24 behind putting that in this 01 l-ine-
25 P e ti t ion? .
Mark LaCour, C.C.R.
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47
1 A. I am outraged. I an outraged.
2 That's what the justification or whatever,
3
4
I don't
Q.
I'm not sure I --
Well, then okay, let. me back up
5
6
7
8
9
10
11
again and see if you -- you WOl~ agree
that you could not pick up the phone and
call the judge and talk to the judge about
the case, right?
A. Absolutely, agree.
Q. And you couldn't ev en pick up
the phone and call the judge a pd say I
12 totally disagree with your rul ing and this
13 is what's wrong with your ruling and
14 you're giving no juitice to these
15 children. As an attorney representing a
16 party in the case you couldn't do that;
17 right?
18
19
20
A.
Q.
A.
Well, --
You would agree witn that?
Except to the degree that I took
21 w r its.
22 Q. Well, sure, but that involves
23 notice to the other party and they --
24
25
-A.
Q.
Right _'.
-- have the opportunity to
ASSOCIATED REPORTERS, NC.
Mark LaCour) C.C.R.
(225) 216-2036
265
Sworn Statement of Joyce McCool Maroh 2 2012
48
1 respond if given that opportunity or
.2 wha tnot.
3
4
5
6
7
A.
Q.
A.
Q.
A.
But
I'm talking about - ....
when you asked mE
an ex parte --
No, absolutely not. I am not
8 entitled to any ex parte communication
9 with the judge.
10 Q. Isn't this a request put out by
11 you to actually have ex parte
12 communication through use of inciting
13 third parties to make direct contact with
14 these judge s?
15
16
A.
Q.
I --
Could you see that as being how
17 they felt or how the judges perceived
18 this?
19 A. Well, how are -- my
20 understanding of what an ex parte
21 communication is, is to have communication'
22 with a party outside the presence of all
23 0 the r par tie s .
24.. Q. o r c 0 mmu n i cat ion wit h t h_e
presiding judge.
Mark LaCour, C.C.R.
(225) 216-2036
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Sworn Statement of Joyce McCool March 2( 2012
49
communication.
A. Correct.
"A. Yeah.
A. - - bu t I --
meant. Right, that's what A.
Communication with the presiding judge,
Q. But it also says can't
Q. I'm asking the ques _ions that
between the presiding judge and a party
Q. Okay. And I'm askir g .. Again I
told you, and hopefully I put on the
outside the presence or knowledge of the
other parties.
record, I have not drawn any c)nclusions.
okay.
came to me from reviewing the
A.. And I don' t want to think
that I'm trying to be difficult
Q. Sure.
Q. No, you're not. I think you're
being forthcoming. 'There is -- there is a
rule in the Rules of Professional Conduct,
8.4A, that says lawyers cannot violate the
rules of professional conduct okay, so
one of the rules would be ex p3.rte
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50
violate or attempt to violate the
acts of another person.
A . And I g u e s s,. you k n w, tot h e
degree that if I had gone to some" third
party,'you know, whether it the most
logical or the most, you know, feasible
way that I see this is if I knew someone
who knows the judge and I go that
.person and say, hey, you know, I've got
this case, I know you're buddies, you
know, can you drop a bug in ear,
jus t so r t 0 f d r 0 p a few w0 r d s n d see, you
know, just kind of -- that I would
consider inappropriate. If -- in this
instance I didn't feel that it was ex
par t e c 0 mmu n i cat ion . I was sur p r i sed a t
the allegation of ex parte
because first and foremost we encourage
people to draw their own conclusions. We
gave them the information, we gave them
the evidence and we said form own
opinion, and then if you feel strongly
about it share your opinion, your
independent-opinion of thatwj th the
judge. I guess I see judges as public
Mark LaCour, C.C.R. .
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51
1 officials. If I understand this correctly
2 they're elected both in Mississippi and
3 Louisiana. They answer to the public.
4 The public has a right to tell them how
5 they feel. And I guess -- oh boy, I'm
6 getting on a soap box now, when the
7 judicial -- when it comes to the.judiciary
8 they have such incredible immunity that
9 they somehow feel like they don't have to
10 answer to th.e public. And I strongly
11 that when it comes to family
12 law that hearing from people about what's
13 going" on is a part of what make them
14 better judges. But I don't consider it an
15 ex parte communication unless I told all
16 those people this is what you need to tell
17 them, and I didn't.
18
Q. Okay. I understand you didn't
. 19
tell that sounds reasonable You
20 didn't ask them call me first so I can
21 tell you what to say?
22
23
A.
Q.
No.
You said read this if you're
24 h 0 r r i fie d , . que s t ion -mark, the I call the
25 j u d g e sand let the m k now . I s :- t f air for
Mark LaCour, C.C.R.
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Sworn Statement of Joyce McCool March 2P. 2012
52
1 me to say that your intent was then to'
2 provide them with this information to
3 elicit some reaction from them and have
4 them voice that reaction to judges?
5
6
A.
Q.
Yes.
At some point there were
7 people were allowed to kind of sign
8 onto this petition online, --
9
10
A.
Q.
Yes.
-- you know, and there was a
11 tally being taken, a number, oE how many
12 signatures that we've gotten. And 'then at
some point the decision was ma::le to

13
14 actually fax the petition. I t know
15 if that included signatures or not but the
16 petition with a number telling how many
17 people had signed at least to lrudge
18 Amacker and to Judge Gambrell.
19 A. Ye ah .
20 Q Who did t hat and when and why
. 21 did t hat 0 c cur?
22 A. I honestly don't knew whether
that was -- it wasn't me and I'm not --
.. 24 r'm not sure. if .. itwas sent to both judge-so
25 or whether it was just sent to Judge
Mark LaCour, C.C.R.
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March 120,2012
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1 Gambrell.
I'm not aware that it was -- I
2 mean I'm not sure but that was probably
3 either Raven or Raven's mom wlo did that.
4 q.
Wasn' t it, and I could look back
5 and see, but my recollection: s that it
6 was sent to JUdge Amacker -- at least to
7 Judge Amacker because wasn't she the one
8 that sent it back directly to you saying
9 please instruct your client n1bt, to engage
10
in e ~ parte communications w i ~ h
do you
11 recall something like that?
12
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14
15
16
17
A.
Q.
A.
Q.
A.
Q.
I don't.
Okay.
Although it's p.ossible.
Did you know that --
I didn't
Raven was going to be faxing
18 this to these judges?
19
20
A.
Q.
I knew it after the fact.
Would that have bee n a step that
21 you w0 u 1 d h a v e a p prov e d 0 f h a <[ you k nown
22 before the fact? I know this is
23 speculation because you i n ~ know.
24'
25 know that it made me a little
Mark LaCour, C.C.R.
2Cf?-5) 216-2036
Sworn Statement of Joyce McCool March go, 2012
54
1 uncomfortable but I wasn't su roe that it
2 was -- because I was worried about --
3 because I had practiced in frent of
4 Amacker and I don't know that -- you know,
5 I wasn't -- I don't know. You know it
6 made me somewhat but
7
8
9
Q.
A.
Q.
You didn't do it?
I d i dn ' t do it.
And it wasn't faxed from your
10 office?
11
12
13
A.
Q.
A.
No.
To your knowledge?
No, but, you know, have
14 electronic fax but I don't -- I don't
15 think that she could have done it -- nor.
.16 so it couldn't -- no, and it w t from
17 my office.
18 Q. It's your testimony that prior
19 to it being faxed to whomever, Judge
20 Gambrell or Judge Amacker or whoever it
21 was faxed to you had no that it
22 was being faxed directly to them?
23 A. No, not before. I new very
24 shortl.y" a'fterwa"rds and I don't remember
25 how I found ou t. It might been that
ASSOCIATED REPORTERS, ltN<;.
Mark LaCour, C.C.R.
216-2036
55
1 Raven mentioned it to me but I knew very
2 s h 0 r t 1 y aft e r war d s t hat i twa.3 don e .
3 Q. Did you ever say anything that
4 either directly encouraged yOJr client to
5 do that or that you've looked back in
6 hindsight and thought that shp was
7 encouraged to do it by your instructions?
8 A. I can't remember anything I said
9 that was directly encourage hE r but I
10 don't know that I did anything to
11 discourage her, you know, honE stly. You
12 know, there is a lot of frustration with
13 this case and --
14 Q. What is -- why -- and you have,
15 you've afforded yourself the c ppeal route
16 although we discussed at least in the one
17 instance where that not, didn't give
18 the results that y'all were still looking
19 for.
20
21
Q.
A.
Correct.
But you understand how
22 our system is set up, and you to
23 district court and if the ruling is wrong
24 .. and or you-disagree with it OI ....
25 legally and you have grounds to then you
ASSOCIATED REPORTERS, llNC.
Mark LaCour, C.C.R.
(225) 216-2036
213
Sworn Statement of Joyce McCool Marc! 20,2012
56
What I don't understand is or what I'm
A. Uh-huh.
slash social media attack to effect her
court and to the Louisiana SUJreme Court.
I mean you kr ow you have
Correct.
Q. Why also then used online
A.
trying to understand is why t D,e two
Q. And y'all availed yourself of
Q. -- since that's the case you're
involved in, okay, and if she's wrong to
access to appeal Judge Amacke l: --
A. Yeah, well, you know, my initial
A. Right.
appeal and you can go up to tt e circuit
get her ruling overturned, ri rht?
that?
pronged attack.
rulings at the district court level?
try and protect them. So as a general
response to your question that would be my
here and used every available resource to
and appropriate tactic to these kids.
thing that I wanted to say was why not
because we're talking about little kids
answer as to why I would use a ly -ava-i-labl.e.
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ASSOCIATED REPORTERS, ][NC.
Mark LaCour, C.C.R.
216-2036
Sworn Statement of Joyce McCool Maret 20,2012
57
1
2
Whether or not I thought -- I mean at the
moment the -- I think the soc al pressure
3 that, you know, we thought -- because the
4 appeal process is.a long in the
5 meantime the kids are being you
6 know, and they're not bOeing ,P So
7 I think maybe the better answ:r to your
8 question is that our concern that even
9 if we were successf,ul on the c ppeal or the
10 writ it 'was go.ing to take a while and in
11 fact it did. I think it took up two
12 months, two maybe two and a he If months.
13 And even if we had been succeEsful that
14 would have been two and a hali months
15 where these children were bei hg exposed to
16 this trauma and we were just trying to do
17 anything we could to protect hem.
18 Q. Did you ever think that this
19 the kind of social me,dia approach that
20 the r e was s 0 met h i n g wron g wit 1 itor t hat
21 i t j e 0 par d i zed you?
22 A. I wanted to be careful that I
didn't do anything inappropriate. I
-24 lIn d e r s tand t hat ,I m a I a wy e r, d." t hat I
25 h a vet 0 pro t e c t, you k now, t h t my - - I' m
Mark LaCour, C.C.R.
29'55) 216-2036
58
1 very, very, very serious abou_ my own
2 ethics and my own integrity. So -- but,
3 you know, I served in the military, I have
4 a very strong sense of what it means to be
5 a US citizens and I absolutel) believe in
6 being active and pro-active and just
7 standing up and taking a VOiCE. I'm
8 standing up against what I do believe is
9 wrong in an. approp-riate manne ..:' and I
10 didn't see anything wrong with reaching
11 out to other citizens and saying I have a
12 problem with this, 'do y ~ agre e with me,
13 and if you do come join me. I think
14 t hat' s jus t, you k now, i n her e ~ t 1 Y
15 American. So, no, I guess the short
16 answer is no, did I proceed with caution,
17 yes, I did. I had -- I had to have a sit
18 down with myself about whethe ~ or not how
19 involved I wanted to be in drafting the
20 petition. But after considerj ng it, you
21 know, Raven needed my help. She didn't,
22 you k now, she was too c los e t 0 i t
23 emotionally to be coherent so I helped her
24. shape her ideas .. I .. helped "her be more
25 coherent in what she wanted tc say. And I
Mark LaCour, C.C.R.
2ft?5) 216-2036
Sworn Statement of Joyce McCool March two 2012
59
1
2
have no
Q.
I can't regret doing that.
Not that you would have a
3 s p e c i f i c r e colI e c t ion a s you. i the r e
4 today but one of your tweets which I think
5 they're called
6
7
A.
Q.
Yes.
says this, and ip light of
8 what you just said I need you
9 elaborate: I am so goin.g to have to change..
10 jobs after this, come on, I'm risking
11 sanctions by the Louisiana Court,
12 you could be a huge help.
13 A. Because did you my writ
14 application?
15
16
Q.
A.
Yes, I did.
So I was furious when I wrote
17 it. And that was actually the toned down
18 version and I felt like T pushed the
19 envelope on how I could speak --
20
21
Q.
A.
Okay.
to the Supreme Cpurt in that
22 b r i e f .
23 Q. So that comment is reference
24 . to the tone- yo.u -t 0.0 k- in. your brief .to the
25 court, right?
Mark LaCour, C.C.R.
21'2(-5) 216-2036
60
1
2
A.
Q.
To :the Supreme COUI t, ye s .
So I should because I would have
3 otherwise taken it as the apploach I'm
4 taking online with this petit on and
5 soliciting your help is putting me at
6 risk.
7
8
9
A.
Q.
A.
No.
Is that not right?
That's not correct. And in fact
10 when I first got -- I don' t r ~ m r if it
11 was when I got this complaint. I think it
12 was but I actually wrote to Change dot org
13 and I told them, you know, this is an
14 attack against the very foundc tion of what
15 you do. And if this truly get 3 some
16 traction and truly they're alJ owed to say
17 that this was somehow criminal then that's
18 going to, you know, that's something they
19 should be concerned about. So I did write
20 tot hem b e c a use I was t r u 1 y b e 2. i e v i n g . t hat
21 as citizens we have an obligation to stand
22 up and speak out when we see t !lings that
23 webeli eve are wrong .
24 Q. Y.ou._s.aLd it"was "jus f-- rece;ntly
~ that you got the Mississippi record?
Mark LaCour) C.C.R.
295) 216-2036
March 20, 2012
61
1 A. Yes.
I want to say in the last
2 two or three weeks.
3 Q. It would have been after your
4 response to this complaint wh ch was
5 October 17, 2011, correct?
6 A. Definitely.
7 Q. So in there then it is
8 truthfully when you tell me at that time I
9 don't know everything that's in that
10 sealed Mississippi record beccuse I don't
11 have the Mississippi record?
12
13
14 true?
15
16
A.
Q.
A.
Q.
That's correct.
Okay. At that time that was
rhat was true at thE time.
I guess one of the other things
17 I was wondering is how is it wj thout
18 access to the Mississippi recolrd were you
19 comfortable making allegations that Judge
20 Gambrell refused to consider
21 A. Well, I guess I saw this as
22 R a v en' saIl ega t ions .
23 Q. That's based on what she told
24 you ? .. _ - -_.. .
25 A. Right. And the petition is not
Mark laCour, C.C.R.
216-2036
Sworn Statement of Joyce McCool March 20. 2012
62
1 a legal document. It's a peti tion. It's
2 a civilian -- a citizen speak ... ng out. So
3 I felt like those -- I didn't have to be
4 -- I do tend to be very anal apout how do
5 you know that, where did that come from.
6 I'm not going to say that I am
7 not a b sol ute 1 y c e r t a i n i s t r u But tho s e
8 were R a v en' s - - t hat', s was R a \j en' s
9 perception of what had happenpd. And I
10 felt very comfortable helping her get her
11 voice out there. I didn't have a problem
12 with that.
13 Q. Tell me a little about this
14 so-called hearing that Judge (ambrell had
15 where she ordered you to come to
16 Mississippi and appear in CaUl t to
17 determine whether or not your actions were
18 in contempt of that ruling. First off, I
19 know you didn't go.
20
21
A.
Q.
I did not go.
Were you -- did you receive
22 notice of that hearing?
23 A. Through the mail.
24 Q --". '.. 0 kay. .-
25 A. I wasn't served.
Mark LaCour, C.C.R.
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Sworn Statement of Joyce McCool Maret 20, 2012
63
1
Q-:-.
Tell me then -- wal k me through
2 it from the time when you got your mailed
3 copy 0 f not ice towhat hap pen dand what
4 YO'ur thoughts are about that IDrocess.
5 A. I received notice through
6 regular mail of a hearing ordE ring me into
7 court in Mississippi. From a strictly
8 procedural legal perspective she has no
9 jurisdiction over me, I'm not a party of
10 that case, I have absolutely, you know, I
11 didn't feel that she had the power or the
12 authority to call me into her court. So I
13 didn't go. And that's the short answer as
14 far as, you know, why --
15 Q. Did you also get a ( opy of the
16 order that she rendered that day?
17 A. I know that there's a warrant
18 out for my arrest in Mississippi,
19 absolutely.
20 Q. Is that still as you
21 u n de r s tand it?
22
23
A.
Q.
As I understand it.
So you don't speed through'
24. Mis.s.issippior--
25 . A. I don't even drive through
Mark LaCour, C.C.R.
216-2036
64
1 Mississippi because let me te 1 you on my
2 list of things never to do going to jail
3 is at the very top of it for even reason.
4 Q. So in summary I think wha.t you
5 said is your appreciat'ion was you were not
6 a party in the Mississippi caEe, you're
7 not counsel representing a pa ty in the
8 Mis sis sippica s e, and don' t 1 E ~ t me put
9 words in your mouth, so you stop me or
10 tell me that you agree with this too, and
11 therefore that as neither a pcrty or a
12 counsel in Mississippi nor arp you
13 licensed in Mississippi that ~ ou are not
14 bound by the orders of a Mississippi judge
15 in a Mississippi proceeding?
16 A. If she had served, m ~ .properly
17 then I would feel that I had some
18 obligation to appear. But ShE did not
19 serve me properly.
20 Q . I twou 1 d n' t n e c e s s a r i 1 y h a v e
21 c han g e d you r tho ugh t pro c e s s c: b 0 u t wh e the r
22 or not you were bound by previous orders
23 in the case that you're not involved in,
24 - ~ r i g h t? ._-
25 A. Did not.
ASSOCIATED REPORTERS, [Ne.
Mark laCoUr, C.C.R.
~ ~ 5 216-2036
Sworn Statement of Joyce McCool Maret 20,2012
65

1 Q. But if I understanc you you're
2 saying that had you been prop=rly served
3 you would have felt some
4 appear?
5 A. I would have filed an objection
6 to her jurisdiction.
7 Q. Okay. You would have responded
8 appropriately?
9
10
A.
Q.
Yes.
Have you -- did you would it
11 have even been appropriate fo you to seek
12 out maybe counselor on your own behalf
13 appeal that order of contempt against you?
14 A. I did seek some and the
15 advice I was given was file a
16 against Judge Gambrell.
17 Q. I'm not going to ask you if did
18 that or not.
19
20
A.
Q.
Okay.
All right. Lastly :he things
21 t hat I wan ted tot a 1 k toy0 u a) 0 uti s jus t
22 to get some kind of further explanation or
23 more into the thought process of just a
... 24. hand f u 1 0 f ..7"" - I h a v e
25 MR. MANNING:
ASSOCIATED REPORTERS, l;NC.
Mark LaCour, C.C.R.
216-2036
66
a minute.
A. Yes".
Let's go off the record for just
Q. No, no. Let me -- I've kind of
I mean I' TIL not going
{OFF THE
BY MR. MANNING:
your picture, and now that I've met you I
can see that that's actually you in
Q. -- which is Nanine on
Twitter, and I don't know what your
official name is or what have you, but by
Q. Ms. McCool, I through references
in the complaint and through] inks back
and forth with the petition and whatnot
carne across your Twitter aCCOl nt
to read them all.
yeah, these are me.
all appearances what I found is what
purports to me to be stuff from your
Twitter account, maybe look at a couple of
pages and just see if that looKs to you
like what would be from your official
Twitter account. I do see that: it has
picture.
A. Yes. For a while it was
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ASSOCIATEDREPORTERS, INC.
Mark LaCour, C.C.R.
" (225) 216-2036
2'84
67
1 just tabbed a couple that I wi 11 ask you
2 about before we wrap up here. I've
3 P r i n ted the s e 0 u t, all 0 f t h I P r i n ted
4 out on March the '6
th
of this year, 2012.
5 All right.
6 A. I don't think I've been tweeting
7 a lot lately.
8 Q. On -- and this doesn't give a
9 year but I'm going to have.to assume
10 we' ret a 1 kin gab0 u t Dec e mb e r : 1 th t hat's
11 2 0 11 .
12
13
14
15
A.
Q.
A.
Q.
Yes.
You can tell me if 'm wrong.
It would have to be
And it says Judge is at .
16 it again, turned a four year old child
17 over to a validated abuser. tell
18 me what it will take for: everyone to say
19 enough. Okay.
20
21
. A_
Q.
What was the date?
December 11
th
if that is right.
Does the date above go with -- is this the
23 proper date for this particular message or
-- 24
.25
lS. it--
A. I don't know honest y, but it
ASSOCIATED REPORTERS, lJN"C.
Mark LaCour, C.C.R.
216-2036
Sworn Statement of Joyce McCool Marc 20, 2012
68
1 looks like they're the same way,
2 Dec emb e r 11 th.
3 Q. Oh, I didn't even see the time
4 and date.
5
6
A.
Q.
Yeah, that's right
What was -- what were you
7 re fe r ring to? Wha t happened j n De cembe r
8 of 2011 that would have prompt ed this
9 partic.ular message?
10
11
A.
Q.
I don't know.
Because I know we about
12 an August hearing.
13 A. I honestly don't know. It does
14 seem sort of like an odd date. Wh.at's the
15 one before it?
16 Q. Nothing related to case.
17 There's something on Sandusky.
18
19
A.
Q.
And they're --
This is -- I mean I just pulled
20 i t up and p r i n ted - - p r i n t' all
21 A. I don't know becausE this seems
22 1 ike t hi n g s h a v e s 0 r t 0 f bee n e r y --
23
24
25
Q.
A.
Who's the validated abuser?
Michael Boyd.
What makes him, quote,
Mark LaCour, C.C.R.
216-2036
March 20. 2012
69
Q. Okay.
you send out a tweet can you d rect it to
account you can by naming them.
a specific individual or agency?
You can -- when
I'm not, you know, I just started
A. The tweet I believe goes to .
"validated"?
A. Well, somebody holding a Twitter
Q. But not a finding by law
enforcement or by a court as of yet?
A. All of the children's therapists
and everyone that I've talked to them and
looked at the evidence.
A. As 0 f ye t .
Q. Okay. Y' all are st i.ll pursuing
those ?lllegations in court thcugh or on
appeal?
A. On appeal in Mississippi.
That's actually before the court.
Q' Her e i s - - let mea sky0 u t his
too because I don't know.
them.
Twitter as well andI'm not lOC percent
but I'm fairly certain that if they name
you like i.f the.y "Say at'-symbol N.anine
McCool it goes into an inbox fer me.
t""\
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ASSOCIATED REPORTERS, n ~ c .
. Mark LaCour, C.C.R.
~ 7 5 216-2036
Sworn Statement of Joyce McCool Marc ~ 20, 2012
70
1 Q. So if I had a Twitter account
2 and you knew what my Twitter (account name
3 was you could direct a tweet directly to
4 me by using my Twitter accoun ... name?
5 A. I could, but it's not like an
6 email where it goes and/sits -- I mean
7 Twitter is a constant flow. ~ o I'm not
8 sure what the utility of it is but by
9 mentioning you you do or mEntioning
10 someone else you're much more likely to
11 see that tweet. It's stored in a certain
12 folder.
13 Q. Is there some -- ~ I also
14 know, and gee I'm going to sound very
15 ignorant here in just a second. I also
16 hear that there's followers Ii ke you can
17 follow certain people on Twitter
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19
A.
Q.
Yeah.
-- and if they're following you
20 the n you get not i fie d i f the y b 0 s tane w
21 t wee tor vic e - ve r sa. And I g u := ssmy
~ question is if someone is like me, I'm not
23 following you but you have a t fveet but
24 something... you wo'uld like me to see because-.
25 you've put my Twitter account hame on
Mark LaCour, C.C.R.
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Sworn Statement of Joyce McCool March ~ O 2012
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answer this answer to the best I
Twitter account name?
60 Minutes
I ever know that it's on there or would it
I
If --
So I'm going to try and Okay.
From your understancting.
A.
Q.
A. So on Twitter if YOt follow
there, if I am not following you how would
somehow alert me because you',e used my
Q. Sure, or the Lens, NOLA, the
understand.
someone when you open up your rf'lwitter
don't know.
line but it's'constantly rolling.
account the people that you're following
it's their tweets that are in t he time
so I'm assuming this is about 'Iweeting to
A. Okay. So that would mean that
the Lens NOLA doesn't follow me so my
Lens Nola hook, whatever that j s.
greater possibility that they viII- see it
bec.ause in my-account w.hen some-one. tweets..
my name at Nanine McCool I'll get a little
tweets they're never going to ~ e e unless I
address it to Lens NOLA. There is a
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1 notification that someone has
2 mentioned you in a tweet. Ane so you can
3 go click on that and you can see the
4 tweet. But it's not -- if you don't see
5 it -- you know, you're going to get the
6 notification but it's not you're
7 going to see it in real time.
8 Q. You get the notification but
9 then it's up to you and seek it out and
10 find it? Okay.
11 A. That's correct.
12 Q. Well, that makes sense. All
13 right. So and not knowing whc the Lens
14 NOLA is but there was a tweet here and
15 it's August 24
th
and it says focus your
16 lens on why Judge Amacker won't protect
17 these girls, and it links to the two audio
18 recordings. Okay?
" 19
A. That sounds like something I
20 w0 u 1 d say.
21 Q. And that same day, August 24""
22 2011, a tweet to the Today Show and it
23 says ask the s e j u d g e s why the won' t
.--.24"- .. .. -And .again it lin.ks to the
25 petition and to the two inter"\ iews or two
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1 r e co r-d i n g S 0 f the min 0 r g i r 1 s. What was
2 your goal? I know the goal wi th the
3 online petition wa.s really kind of seeking
4 individual support and signatures. What
5 was your goal with the social media or the
6 tweets and especially the one3 that would
7 have been directed maybe more towards
8 media or news personalities ot people like
9 that?
10 A. So this case is not unique
11 unfortunately. The goal be to bring
12 our nation's attention to how poorly we
13 treat children in the court
14 particularly when there are of
15 sexual abuse. And I believe that there is
16 a terrible failure of our sys1 em to treat
17 those cases in a sensible, lac ical,
18 rational fashion. And as a result
19 children are not being protec ed. Which
20 from, you k now, I W 0 u 1 d t h ink jus t a
21 fundamental perspective of wh3.t we all
22 care about that that would be a primary
23 concern. So the focus was to have some
24 thesoci.al me.dia to. look at this ca..se as
25 an example of what goes on routinely where
ASSOCIATED REPORTERS, ilNC.
Mark laCour, C.C.R.
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Sworn Statement of Joyce McCool . March 2012
74
children's safety and the evidence is
absolutely ignored for reasons that I can
only guess at.
Q. And to bring pressure upon this
case in particular because it was and is
still pending?
A. I can't deny probably that I
wanted to protect these kids end if that
would have it would ha'\ e, but I
want to say that honestly in these
instances -- and what was the date on
those?
Q Aug us t 24
th
.;
A. The -- I really wanted people to
realize that what was going or in this
case was a travesty but that it goes on
it isn't an isolated incident, that it
goes on a lot.
Q. Was it the emergency ex parte
hearing? Is that what took place in
August before this Judge Amac] er?
A. I'm sure it took place in
August. I can't tell you the exact date
.- bu-tI' m sure it was in August. _
Q. And I'll tell you, know,
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Sworn statement of Joyce McCool Maret 20,2012
75
A. Correct.
information in the record, the fact
can discard Mississippi for now but
sealing. the sensitive evidence or
So we
now in Louisiana in a sealed
Q. And so part of the concern is in
say, you know, part of concern I
Mississippi was sealed and you told
me that in the emergency that'
you requested they be sealed pecause of
the nature of the proceedings and the
allegations.
matter because you are the one who asked
from reading the complaint and I'll even
may have about some of this okay, we
it be sealed
l
I assume it was granted. and
was sealed, that now in the pt blic arena
youlre discussing and complaining about
those very proceedings which sealed.
A. WeIll I guess my understanding
of sealing records is that y01 would be
that the record exists itself
I
never and I would not allow tt e drawings
that were submitted.as part 0 ,that:record,
to be made part of the social
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Sworn Statement of Joyce McCool March '0,2012
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Q.
A.
Q.
qkay.
you know, --
So the drawings and none of the
4 excerpts from the journal, nOI e of that
5 was ever
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A.
Q.
No.
-- linked or attached or images
8 uploaded and connected with ar y of the
9 social media sites?
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A.
Q.
A.
No, absolutely not.
Okay.
They're very compelling images
13 but I believe they belong to Harley. So I
14
...
wouldn't -- didn't want to do that to her.
15 Q. And your ~ you s t i ~ l based on
16 your recollection today, is tr at the two
17 audios of Raven speaking with her
18 children, these two, I'm only talking
19 about the two that we have that are linked
20 her e, are not par t 0 fan y r e cor d . The y' r e
21 not par t 0 f the Mis sis sipp irE cor dand
22 they're not part of the Louisiana
23 emergency relief record.
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A.
Q.
_That's.correct.
And you're confident about that?
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Sworn Statement of Joyce McCool March' 0, 2012
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1 Not just to your recollection.
2 A. Right. No, I knew that at the
3 time that I posted them that that was my
4 understanding .that they were not part of
5 the record and that I very fairly
6 confident based on what I knew that they
7 were not part of the record. lind I'm .even
8 more confident now having received the
9 record .even though we weren't allowed. any
10 of the -- Raven wasn't allowed any
11 exhibits so therefore I couldn't see any
12 of the exhibits. It just does l1't look
13 like they were ever -- that an'i1thing was
14 ever
15 Q. How do you appeal tt e trial
16 court without having access to copies of
17 the exhibits in the record?
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A.
Q.
A.
Q.
It's Mississippi, I don't know.
Okay.
I have no idea.
Who is Ron TP? Is
22 that someone with the Times Pi :::ayune?
23 A. . Maybe. I don't .
. 24 Q . . Becaus_e. -this tweet ays at Ron
25 Thibodeaux TP, ask Judge Amacker why 'She
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Sworn Statement of Joyce McCool March PO, 2012
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1 won't listen. And again it links to the
2 two audios and to the online petition.
3
4
A.
Q.
Ye s ( we 11 (. the n I w~ u d gue s s ..
So you don't -- y o u ~ v been very
5 open I think. You'certainly don't deny or
6 I should say you would agree that part of
7 this campaign was to get local and
.8 national media attention on tris
9 particular case, specifically and in
10 general how you perceive the court system
11 treats minor children?
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A.
Q.
A.
Correct.
Okay.
And it's not -- I mE an I think
15 the part that concerns me is the
16 allegation that I'm trying to intimidate
17 anyone. I don't believe that that was
18 ever an intent to intimidate anyone.
19 Q. I might would personally -- I
20 might would choose the word influence,
21 maybe not intimidate. I do think and I
22 will tell you and maybe -- and we've
23 tal ked abo uti tal rea d y but I t h ink t his
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whole" campa.ign: was an effort .to influence
one or both of these judges.
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Sworn Statement of Joyce McCool March ~ 2012
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1 A. But to influence them to do
2 wha t?
3 Q. To either consider this evidence
4 or to --
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A.
Q.
A.
I will agree with that.
Okay.
I will not deny that. I will --
8 it was a campaign to influencE the judges
9 to apply the law and look at the evidence,
10 definitely.
11
12
Q.
A.
Through social media?
Yes, through whate\ er means
13 available.
14 Q. And let me ask you, and I guess
15 after we've talked now the rec son why I
16 would have fla.gged this one, c gain, August
17 24
th
Apparently there was a lot of
18 tweeting on August 24
th
, but August 24
th
:
19 hear what Judge Gambrell and L udge Amacker
20 refuse d t 0 h ear, 0 kay, but t h ~ sis ali n k
21 to something on Sound Cloud ar d something
22 else. I'm not sure what that was and I
23 h a v en' t --
24 .
25
'.. A._.-
Q.
I think it was the same --
Same audios?
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1 A. Same audio. I know it was the
2 same audio because I didn't post any other
3" audio so that would have to be what it is
4 and
5 Q. Did you -- did you a nd your
6 client ever offer those audios' to Judge
7 Amacker, offer them into evidence? We
8 have them here, they'are tapes and we have
9 them available and we're offering them
10 into the record?
11 A. When we went to the ex parte
12 hearing, right, we gave our dr3.ft of the
'13 petition. I gave Mr. Boyd's a' torney --
/
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18 sent
Q.
A.
Q.
A.
Who is it?
Meg Kern. Margaret Kern.
Margaret Kern, okay
In the adoption proceeding. We
I don't remember if we sent it to
19 him directly or if we sent it to.her. She
.20 was n' t his a t tor n e yin the s e p" 0 C e e ding s
21 s 0 I In i g h t h a v e d ire c t 1 Y t 0 h i I1 and the n
22 gave him a call. That's what the rules
23 require, to let him know that \'I e were
24 .go-irrgto .go to court on these
25 We were in court all day. Raven was with
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1 me. And the -- how they do it in St.
2 Tammany i 5 you b ring yo ur ex part e
3 petition, and they don't like ex parte
4 petitions and with good reason, you bring
5 it to the clerk. You have to bring it
6 upstairs to the judge's chambers. They
7 look at it and make sure it's the proper
8 form and say yes or no whethel or not
9 they'll even entertain it and then you
10 i f the y say 0 kay the n you t a k E .i t b a c k
11 down to the clerk. The clerk stamps it
12 filed in and then you go up and you sit
13 and wait to see the judge. And what
14 you're asking for is an
15 hearing at that point. You al e saying I
16 want to put on evidence to sUI port this ex
17 parte hearing or I want you tc sign my ex
18 parte order and then set a hee ring date.
19 Either one we were prepared to go forward
20 and e i the r she - - 5 he, J u d g e ]. mac k e r ,
21 aft e r - - e'5 5 e n t i a 11 y she den i ed U s the
22 hearing. So we were there ane we did get
23 to
24-._ .. .Q.
Sow..ere you alloweeto a.r,g..u.e' on
25 b e h a 1 f 0 f tryi n g t 0 5 e cur i n g ci n e x par t e
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hearing?
A. She spoke with us off the
record.
Q. In chambers or in tlhe court?
A. In the courtroom at her bench.
Q. You and Ms Kern?
A. I don't think it Ms. Kern.
It was an associate in her office whose
name I can't remember.
Q. Okay.
A . And she - - I t h ink he s aid
oh, she said she would take it under
advisement but she never alloy., ed us to put
on any evidence. And then the next day
got her notice that she was the
motion.
Q. And not that this w<as your
intent I will just say that from
someone not having all the details of this
like myself reading this I clearly get the
impression that here, listen to these
tapes we have them and we've them to
the court. The court just to
listen to.. them and.yo.u didn't .Sa", thaOt .
I'm saying that's what I take Nhen I read
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1 this over and over again and that's
2 exactly what I think it means.
3 A. Well, I think it means that I'm
4 telling the judge, look, I ha'le evidence,
5 we'd really like for you to look at the
6 evidence and then if you make a decision
7 based on the evidence, you know, that's
8 appropriate way to do it. I might not
9 agree with your decision but first look at
10 the evidence. And the fact that they
11 won't give us the opportunity to put the
12 evidence before them is the same thing as
13 saying here it is and then to
14 look at the evidence.
15 Q. All right. August 6 th you t wee t
16 judges are supposed to know shit about the
17 law, aren't they, and like evidence'and
18 shit, due process, question mark. And
19 then you link the petition.
20 A. What was the date on that? Boy,
21 I wa s mad.
22
23
Q.
A.
Aug u s t 16
th
Did I curse on Twit1 er? I was

24 really mad.
25 Q. Wasn't that the act p,al day of
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the hearing or a day of one of the orders
t hat weI 0 a ked at? Aug us t 16
th
A. Could have been.

, Q. Do you remember wha _ was going
on in August that set you off?
A. It was right around the dat'e --
I know it was right around the date of the
evidentiary hearing. I honestly don't
remember making that tweet but clearly I
did. I'm not denying I did it. It's
under my name so I made it but --
Q. Who are you referrir g to? Judge
Amacker? Was this a hearing?
A. Does it say judges?
Q. It says judges plurc 1.
A. I might have been just talking
about judges in general. I COt Idn' t say.
It could have been either one c f them --
Q. What are your--
A. -- or all 'of them.
Q. What are your genera 1 thoughts
about attacking the integrity )f a judge
or judges through social media?
A . The int e g r i ty of aspe c i fie
judge?
ASSOCIATED REPORTERS, n ~
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Sworn Statement of Joyce McCool March :;lO,2012
85
1
2
Q.
A.
Sure.
oh , I t h ink t hat I ,., 0 u I d pro c e e d
3 very cautiously before I aCCUE e any
4 specific judge of anything inappropriate.
5 Speaking in general terms of my
6 frustration you know, we have good
7 lawyers, w'e have bad lawyers. We have
8 .good judges, have bad judges.
9 Q. Is it your testimon IT today that
10 you carefully worded this so that it was
11 not made or intended to be a s]; ecific
12 attack against a specific
13 A. Yes, I would say that I would be
14 very careful about naming a naJne and --
15 because I am very aware that I'm very
16 passionate about this and that my
17 perspective is my perspective. I respect
18 the very difficult job that judges
19 have and I try to stay in touch with that
20 even when I'm fur i ous.
21 Q. All right. This is last
22 tweet that I'm going to ask you about
23 t 0 day . Itsa y s g i v e me, g i ve me, g i .v e In e
24 e v iden c e . 1..' -m s.o r ..r-y .' Thedate 0 fit i s
25 August 16
th
Told you August a busy
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2
3
A.
Q.
There was a lot going on.
Give me, give me, give me
4 e v ide n c e . Wan t s 0 me, que s t i 0 mar k . I
5 got it. Think you can convince a judge to
6 look at it, and then you link to the
7 petition. Now this was part of what I
8 talked about earlier whenever I said and
9 it was my word I used, an to
10 influence the judge, okay. And you linked
11 to the petition, right? The
12 which gives a brief summary from
13 admittedly from your client'sperspective,
14 you and your client's perspective, not
15 only just her version but what you think
16 the evidence and the facts were up to
17 date, okay? And links to the c udios from
18 the petition?
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A.
Q.
Yes.
And gives both names and
21 contact allan the petition,
22 right?
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A.
Q.
A.
Okay. Yeah.
You f.ollowme?
I do agree.
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Sworn statement of Joyce McCool March 20, 2012
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1 Q. And this says give me, give me,
2 give me evidence, want some, got it,
3 think you can convince a judgE to look at
4 it. I think we already covered this
5 because I think you said it was fair and
6 you would that yOl r effort
7 through this was to, even using my word,
8 influence the judge to look at the
9 evidence that y'all wanted to present,
10 right?
11
12
A.
Q.
Yes, absolutely.
And you had tried to get Judge
13 Amacker at least to do that at the ex
14 parte hearing but your efforts to get an
15 evidentiary hearing was deniec,right?
16
17
. A.
Q.
Th'at' s correct .
So you wanted to influence her
18 to change course and actually
19 entertain, accept the evidence that you
20 were tryi n g topres e n t ?
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A.
Q.
A.
Honestly?
Yes.
Frankly I wanted in my opinion
24. fo..r her. to-j list fo-l-low the law. The law
25 allows and should demand when re
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1 talking about the best of the
2 children that evidence be
3 before you deny relief. And yet --
4 Q. Do you think that -- it's a
5 loaded question, actually a se ftball. Do
6 you think judges can make mistakes legally
7 and/or factually?
8
9
10
11
A.
Q.
A.
Q.
Never.
Well, I mean obviou$ly --
Of course.
they can and we }now that and
12 they do.
. 13
14
A.
Q.
Dh-huh .
And they're human like
15 just like I am.
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A.
Q.
A.
Q.
Correct.
Okay.
Yes.
Which is what the process
20 is for?
21
22 j ob .
23
A.
Q.
Correct, and they a tough
And again I told yOl before we
24 got .st.ar.ted that really I am n)t getting ... :
25 into the merits or even the al .. egations as
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1 salacious as they are of the underlying
2 case as serious as those are.
3 I'm looking at it from a different
4 perspective. And one of the perspectives
5 that I have is you sought the emergency
6 you were denied that evidentiary
7 hearing, and writs were taken to the First
8 Circuit and 'Louisiana Supreme Court who
9 both denied which ended it from a legal
10 standpoint, at least that particular issue
11 on that particular day.
12
13
A.
Q.
Correct.
, 0 kay . That's 0 u r s t em. We
14 like it or not that's our And I
15 think part of what I take from the
16 complaint is we used the word Erustration
17 a lot, your frustration. It m:iY be the
18 judge's frustration or perception of
19 having an end around even usin'g the system
20 that we have and even you know,
21 my rulings our system is not up to
22 a 11 0 w par tie s 0 r c 0 u n s e 1 toma k: e end
n arounds using social. media to to
24 . influence us especially,.,.in.
25 1 i g h t 0 f the f act the y , v e aIr e :i d y a v ail e d
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We are all citizens. We all OFn thi-s .
have checks and balances, carl ect, and
judicial system, the justice ystem does
it isn't. I mean I think, you know, the
not set up
It's just in the past
whether our system is set up
themselves of the appeal
A. So my response to that is that
that way and I'm not -- I'm aware that
society at large involved in any
people bringing attention and getting
that's what the appellate proc ess is. And
that's one means of accomplis!" ing justice.
But I think we have a long his tory of
particular case .to get the judicial
evidence of that.
the justice system to work more
efficiently and I think there's lots of
government. We're all part of this
year the Memphis Three were just released
because of tremendous social that
was brought to have that looked at again
and again. And it took years. So I don't
think that our system excludes the
involvement of the citizenshif nor should
it. This is the United States of America.
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Sworn Statement of Joyce McCool March 0.2012
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you know why I became an
it would be in the justice sys _em. And
matter how annoyed I'm sure was with
I'm an attorney I'm not aware that I have
I don't
I .d 0 n 't. t h ink. t h e.r e was a ny t h i n 9
government. We have a right to stand up
and say we don't agree. And j 1St because
been deprived of my right to have an
opinionabout whether or not the system
works well particularly for children. And
Because I thought that if was any
place where kids would haye a shake
that's not been my experience and it's
,
t h ink t hat's, you k now, why I :> e r v e q my
frustrating. But -- and I bel eve in
standing up for what I believe in .. I
country so I have that right.
think that I guess I don't t:nderstand
why if you're why judges -- and I
understood Judge Amacker has not
complained at least not formally. No
me in particular because I don t think
that it is -- I don't believe that Judge
Gambrell was intimidated by anvthing we
did.
intimidating by what we did. Pnd I don't
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Sworn statement of Joyce McCool
March :20,2012
92
1 think encouraging judges to follow the law
2 and to look at the particularly
3 when there are children invol, ed is a
4 terrible thing.
5 Q. Well, I will say that I do think
6 you've been very forthcoming and you've
7 been cooperative.
8 MR. MANNING:
9 Let the record reflect that Ms.
10 McCool appeared here t6dc y
11 voluntarily pursuant to IflY request
12 without requiring a subpc ena and has
13 been fully cooperative tc this point.
14
15
16
17
18
19
I do appreciate it. Those are all
the questions I have for the record
and we can conclude now.
THE SWORN STATEMENT ENDED 10:50 A.M.
* * * * *
Mark LaCour, C.C.R.
(225) 216-2036
310
March 0,2012
93
REPOR"TERrS PAGE
I, Mark LaCour, Certified ourt
Reporter, in and for the State 0 Louisiana,
the officer, as defined in Rule 8 of the
Federal Rules of Civil Procedure and/or
Article 1434 (b) of the Louisiana Code of Civil
Procedure, before whom this swor testimony
was taken, do hereby state on th record:
That due to the interactio in the
that
pauses,
spontaneous discourse of this ceeding,
dashes (--) have been used to in
changes in thought, and/or talk
same is the proper method for a Court
Reporter's transcription of proc eding, and
that the dashes (--) do not indi ate that
words or phrases have been left out of this
/
\
{
"
transcript.
Also, any words and/or names which could
C.C.R. Mark.
#
Mark LaCour, C.C.R.
(225) 216-2036
311
" (i na u d i b Ie) . "
have been denoted with the phras
not be verified through referenc material
94
1 C E R T I FIe A T ION
2 I, the undersigned reporter, do hereby
3 certify that the above and foregoing is a true
4 and correct transcription of the stenomask"
5 tape of the proceedings had here'n, taken down
6 by me and transcribed under my s pervision, to
7 the best of my ability and tanding, at
8 the time and place hereinbefore oted, in the
9 above-entitled cause.
10 I further certify that the witness was
11 duly sworn by me in my capacity .... s a Certified
12 Court Reporter pursuant to the p ovisions of
13 R.S. 37:2551 et seq. in and for the state of
Louisiana; that I am not of coun el nor 14
15 related to any of the counsel of of the
16 parties, nor in the employ of an of parties,
17 and that I have no interest in the outcome of
18 this action.
in and for
# 89054
_. Ma r k
OFFICIAL SEAL
MARK LACOUR
C:ortiflQd Court
In Jnd for tho Sbll. of Louisiana
Corif11e<lbl Numbor
COrtlflcatA explreI12-31.12
good standing as a court
23
20
25
22
21 the s tat e 0 fLo u i s iana .
19 I further certify that my l'cense is in
" 24
ASSOCIATED REPORTERS, C.
Mark LaCour, C.C.R.
(225) 216-2036
312
~ .
~
..
,
In The Matter Of:
INRE: JOYCE NANINE MC;C(DOL
28469
JOYCE NANINE MCCOOL
March 20,2012
AssociatedReporters Inc.
2431 South Acadian Thruwav
oJ
Suite 550
Baton Rouge, LA 70808
(225) 216-2036 Fax (225) 2 1 6 ~
~ 2 2 0
--
-.
Original File Mccaa1.TXT
.l\'l1iu-"lJ-Script "vitI! 'l/ord Jf!mdl-x
313
f)'
+0,' .... _.:
This Page Intentionally Left Blank
314
..
:rnRE: JOYCE NANINE MCCOOL JOYCE NANINE MCCOOL
28469
March 20, 2012
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Min-U-Scritlt
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r.
(2:Z5) 216-2036 .
JOYCE NANINE MCCOOL
March 20, 2012
IN RE: JOYCE NANINE MCCOOL
. 28469
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(225) 216-2036
Mtn-U-Scrifit
28469
JOYCE NANINE MCCOOL
March 20, 2012
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Reporters Inc.
216-2036
(3) coaching - drawings
JOYCE NANINE MCCOOL INRE: J DyeE NANINE MCCOOL
March 20,2012 28469
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(225) 216-20
28469
JOYCE NANINE MCCOOL
'March 20, 2012
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1\1 iu-U-Scdpf Reporters Inc.
(225) .;216-2036
(5) forthcoming - intimidated
JOYCE NANINE MCCOOL
INRE: J( NANINE MCCOOL
March 20, 2012 28469
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(225) 216-2036
.. . .
JOYCE NANINE MCCOOL
28469
March 20, 2012
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13 54:25;78:19,20; 3:9 73:8 25;39:8;40:13,16;
Maurer (3) 80:21;83:8;84:16 most (3) next (3) 41:14;43:10
4:14,17;10:1 Mike (1) 40:4;50:5,6 29:16;: 3:2;82:14 offering (2)
M-A-U-R-E-R (1) 31:1 mother (4) nine (1) 39:5;80:9
4:15
military (4) 17:2;21:10;35:23; 24:1 Office (14)
may (3) 8:14,18;13:22; 36:10 NOLA(5l 3:11;5:14;7:10,20;
33:12;75:3;89:17 58:3
. motion (7) 71:17,] 8,20,22; 13:19;14:10;32:6,7;
maybe (15) mine (1) 16:8,23;22:13; 72:14 33:17,19;34:23;
12:1;15:6,7;17:22; 24:19;27:3,17;82:16 non-comj liant (1) 54: 10,17;82:8
28:6;38: 10;42: 14; minor (8) mouth (1) . 21:12 officer (1)
57:7,12;65:12;66:15; 7:15;17:10,14; 64:9 none (2) 93:4
73:7;77:23;78:21,22 19:5;20:15;35:16; move (1) 76:3,4 official (2)
MCCOOL (9) 73:1;78:11 30:5 non-profi t (3) 66:12,17
3:2,9;7:23;45:24; minors (1) moved (2) 32:18,19,25 officials (1)
66:5,10;69:25;71:25; 6:12 22:3,9 nor (2) 51:1
92:10
minors's (1) much (4) 64:12;S0:22 often (1)
mean. (17)
44:4 7:16;33:16;35:13; . notice (6) 20:19
7:15;11:12;19:19; minute (3) 70:10 :23;62:22; old (1)
29:4;36:4,15;41:23; 27:22;34: 19;66:2 must (1) 63:3,5; 67:16
53:2;56:5;57:1; Minutes (1) 44:21 notificati tm (3) oldest (1)
66:23;68: 19;70:6; 71:16 myself (2) 72:1,6, 24:1
71:19;78:14;88:9; Mississippi (69) 58:18;82:20 notified ( ) once (4)
90:5
3:16,19;4:22;6:3; 70:20 26:24;31:7;38:8;
means (5) 9:25;10:3,13,16,22; N number (12) 40:24
58:4;79: 12;83:2,3; 11:2,4,10,15,16,17, :7,16;26:4, one (18)
90:9 18,24;12::7)1,13,14; name(18)- ,4,8,10,12; . 11:19;23:18; - .
meant (4) 13:5,25;14:2,8; 3:10;4:8,13;5:3; 6 . 34:14;35:16;49:22;
38: 16;39:6;41:3; 15:12,13;16:1,20; 7:7,20,22,24;66: 12; numbers

53:7;55: 16;59:4;
49:1
17:22,23;18:2;22:10; 69:23;70:2,4,25; 86:21 61: 16;68:15;75:13;
meantime (1) 23: 17;24:9;27:15; 71:4,25;82:9;84:11; 78:25;79:16;81:19;
57:5 29:14,23;36:25;37:9, 85:14 0 1,18;89:4;90:9
meat (I) 16,21;38:8;39:13; named (2) ones (1)
34:21 40: 11,24;42:8;46:3; 4:7;10:23 object (2 73:6
media (11) 51:2;60:25;61:10,11, names (5) 12:22; 0:17 ongoing (1)
3:23;56: 16;57: 19; 18;62:16;63:7,18,24; 44:4,20,24;86:20; objectiolJ (4) 27:11
]\rlin-U-Script@ Assoc1l&l Reporters Inc. (7) manner - ongoing
(225) 216-2036
JOYCE NANlNE MCCOOL
March 20, 2012
IN RE: NANINE MCCOOL
28469
6: 16, 19,23;7: 16;
13:25
practiced (1)
54:3
predate (1)
36:22
preliminary (1)
15:8
prepared (2)
31:24;81:19
presence (2)
48:22;49:4
present (4)
41:18;44:11;87:9,
20
presented (3)
25:25;40:10;43:10
presiding (4)
10:5;48:25;49:2,3
pressure (3)
57:2;74:4;90: 18
presume (1)
35:22
pretty (3)
7:16;18:4;37:11
prevent (1)
29:14
previous (1)
64:22
primarily (2)
6:19,20
primary (1)
73:22
print (1)
68:20
printed (3)
67:3,3;68:20
prior (1)
54:18
privilege (1)
17:19
pro (1)
10:19
pro-active (1)
58:6
probably (9)
9:17;14:4;19:2;
25:16;33:1;45:2;
46:14;53:2;74:7
problem (2)
58:12;62:11
(1)
63:8
procedurally (1)
26:7"
procedure (3)
11:11;93:5,7
proceed (2)
58:16;85:2
proceeded (1)
26:5
proceeding (24)

81:3;83:19;86:7,1 ,
11,18,21
petitioner (1)
5:24
petitions (2)
28:9;81:4
phase (1)
28:22
Phillips (4)
16:25;17:1,6,12 .
phone (8)
36:12,13;46:4,8,9,
12;47:6,11
phonetic (1)
11:13
phrase (1)
93:20
phrases (1)
93:16
physical (2)
7:10;31:25
physically (1)
34:19
Picayune (1)
77:22
pick (2)
47:6,10
picture (2)
66:19,21
place (7)
28:21;29:2,3;
36: 18;74:20,22;91. 9
platform (1)
43:14
pleadings (2)
13:7;19:4
please (2)
53:9;67:17
plural (1)
84:15
point (11)
14:7;15:6;28:3,24;
29:7;30: 19;38:4;
52:6,13;81:15;92: J3
pooriy (1)
73:12
portions (2)
12:17,18
position (1)
46:18
possibility (1)
71:23
possible (1)

post (2)
70:20;80:2
posted (1)
77:3
potential (1)
33:14
. power (1)
63:11
practice (5)
48:22;49:3;50.:5;
63:9;64:6,7,11
passed (1)
10:8
passionate (1)
85:16
past (1)
90:16
path (1)
29:20
Patricia (3)
11:1,13,25
pauses (1)
93:11
pay (2)
9:10;21:5
paying (1)
21:13
pending (2)
46:20;74:6
people (13)
28:12,14;32:21;
50: 19;51: 12, 16;52:7,
17;70:17;71:l2;
73:8;74: 14;90: 11
perceive (1)
78:10
perceived (1)
48:17
percent (1)
69:22
perception (2)
62:9;89:18
period (1)
31:11
person (4)
17:12;19:8;50:2,9
personal (4)
5:10,12;7:4,5
personalities (1)
73:8
personally (1)
78:19
persons (1)
17:6
perspective (8)
42:1;63:8;73:21;
85:17,17;86: 13,14;
89:4
perspectives (1)
89:4
Pethee (1)
11:12
_
:9,18;
22:23;28:3;31:8,14;
32:1;33: 11;34:20;
35: 11;38:1;39:11;
42:9;43:24;44: 17;
46:25;52:8,14,16;
58:20;60:4;61:25;
62: 1;66:7;72:25;
73:3;78:2;80:13;
67:17;83:1,1
overs (1)
93:12
overturned (1)
56:10
own (6)
50:19,21;58:1,2;
65:12;90:24
ownership (1)
45:3
owns (2)
34:2,4
p
page (1)
44:17
pages (2)
35:14;66:16
paid (1)
30:12
paper (1)
31:5
paragraph (1)
45:1
parent (7)
21:5,12;29:25;
30:5,12,16;31:7
parental (2)
30:1,6
Parish (2)
44:1;46:7
part (25)
14:11;15:23;
29:24;36:21;37:8,14;
39:25;40:5,6;42:18;
51: 13;75:2,11,24,25;
76:20,21,22;77:4,7;
78:6,15;86:7;89: 15;
90:25
parte (22) .
22:22;28:25;43:1,
7;44:9;48:6,8,11,20;
49:22;50:16,17;
51:15;53:10;74:19;
80:11;81:2,3,17,18,
25;87:14
participated (1)
28:19
particular (9)
15:19;67:23;68:9;
74:5;78:9;89: 10,11;
90:13;91:21
particularly (5)
28":15;51:11; ",-.
73:14;91:6;92:2
parties (6)
.17:10;19:11;
48: 13,23;49:5;89:22
partner (1)
6:21
party (10)
6:2;47:16,23;
online (15)
28:3,8;32:2;33:10;

2:9;43:23;46:24;
52:8;56: 15;60:4;
73:3;78:2
only (11)
11 :21;18:5;37:12;
39:2;40:9,12,14;
42: 13;74:3;76: 18;
86:15
onto (1)
52:8
open (2)
71:11;78:5
operates (2)
33:22;34:1
operation (1)
8:22
opinion (5)
50:22,23,24;87:23;
91:5
opportunity (4)
12:12;47:25;48:1;
83:11
oppose (1)
16:22
order (16)
15:25;16: 13,15,16;
17:5; 18:4,6,9; 19: 1,9;

,:13;81:18
t1J.l1ered (4)
21:5;24:2;30:13;
62:15
ordering (1)
63:6
orders (3)
64: 14,22;84: 1
org (7) .
28:5;32:17;33:23;
34:5,8;35: 12;60: 12
organization (2)
33:1;34:10
original (1)
10:7
Orleans (2)
3:3;8:1
otherwise (2)
60:3;89:24
out (21)
7:2,3;J 1:5;25:16;
32:4;38:22;41:21;
42:6;48: 10;54:25;
. 58:11 ;60:22;62:2,11;
63: 18;65: 12;67:3,4;
69:15;72:9;93:16
outraged (2)
.....4.7:1,1

'-.- ..d:22;49:4
over (6)
10:6;30:6;63:9;
online - proceeding (8) Associated
(225) 216-2Y.5t -
1VHn-U-Script
..........
INRE: JOYCE NANINE MCCOOL JOYCE NANINE MCCOOL
28469 March 20,2012
25;23: 12,19,23; 17:4 62:21 released restarted (1)
24: 15, 17,20,21;25:8, quote (2) received (2) 90:17 27:19
9,15,24;27:18;36:22; 16:17;68:25 63:5;77:8 relief (4) result (2)
42:20;43:11;64:15; receiving (1) 16:12; i76:23;88:3; 15:2;73:18
80:17;93:10,14 R 21:21 89:6 results (1)
proceedings (19) recently (1) R-E-L-L (1) 55:18
4:6,21;12:19; raised (2) 60:24 3:15 review (4)
20:22,22;23:1,6; 8:9;21:15 recollection (4) (1) 12: 13,15;20:9;
27:9,12;29:24;36: 18, rather (1) 53:5;59:3;76:16; 22:3 24:9
20,23;37:9;75:6,8, 26:15 77:1 remain ( ) reviewed (1)
17;80:20,24 rational (1) record (52) 27:14 17:20
process (11) 73:18 3: 18,21;7:21; remarried (1) reviewing (1)
5:18;31:9;57:4,4; rationale (1) 12: 11,13,14,21; 13:9; 4:10 49:11
63:4;64:21;65:23; 46:23 14: 17;15: 15;17:21; remembE r (12) rewarding (1)
83:18;88:19;90: 1,8 Raven (43) 19:16,18;20:5,9,13; 7:1;12:8;13:20; 9:17
Professional (2) 4:7;5:7,16;6:7; 22: 16,21;23:4;29:4, 5:4;54:24; right (50)
49:19,21 10:1,21;11:14,17; 6;37:14;39:13,15,20, 55:8;6( :10;80:18; 5:15;6:2,10,14;
prompted (4) 12:9,22;13:17;15:6, 22;40:5;42:8,11; :4,9 7: 19;1'5:20;20:15,17;
18:3,6,9;68:8 22;16:19,25;17:5,11; 43: 11;49:8;60:25; rendered (1) 23:10;26:1;27:21;
pronged (1) 20:10;21:21;22:7; 61:10,11,18;66: 1,3; 63:16 28:2;30:7;31
56:5 24:7;28:11;33:17; 75:21,22,24;76:20, repeated y (2) 32:4;36:5;39:1;
proper (3) 35: 17,20,23;37: 1,22; 21,23;77:5,7,9,17; 19:19;r 7:15 42:17;43:19;45:21;
67:23;81:7;93:13 39:5,17,23;41:17,21; 80: 10;82:3;92:9,15; Reporter (1) 47:8,17,24;49:1;
properly (3) 45:10,12,14;53:3,17; 93:8 93:3 51:4;56:10,11;59:25;
64:16,19;65:2 55:1;58:21;76:17; recorded (1) Reporter s (1) 60:8;61:25;64:24;
protect (8) 77: 10;80:25 36:13 93:14 65:20;67:5,21;68:5;
19:5;29:18;44:3; Raven's (10) recordings (18) represen (5) 72:13;77:2;80:12;
56:22;57:17,25; 17:2;21:15;38:9, 36:10;37:20,23; 5:1,6,7 21;17:21 83: 15;84:6,7;85:21;
72:16;74:8 15;40:25;41:2;53:3; 38:4,10,20;39:3,11; represen ing(4) 86: 11,22;87: 10,15;
protected (2) 61:22;62:8,8 41: 1,7,8,12;42: 12, .5:11;1 :25;47:15; 91:1,4,15
51:6;73:19 reaching (1) 17;43:5,9;72:18;73:1 64:7 rights (5)
provide (1) 58:10 records (4) represen fs (1) 30:1,4,6,9,25
52:2 reaction (2) 20:18;38:2;40:11; 10:21 risk (1)
provisions (Il 52:3,4 75:19 request ( 60:6
26:19 read (9) refer (2) risking (1)
public (5) 4:3;12: 16;16: 13; 7:5;11:17 92:11 59:10
50:25;51:3,4,10; 40:21;45:7;51:23; reference (3) requestec (1) road (1)
75:15 59: 13;66:24;82:25 44:8;59:23;93:19 75:7 9:16
pull (1). reading (4) referencC$ (1) require ( ) rolling (1)
25:17 38:18;41:9;75:1; 66:5 80:23 71:14
pulled (1) 82:20 referring (2) requires 1) Ron (2)
68:19 real (4) 68:7;84:12 44:5 77:21,24
purports (1) 25:17;31:20;35:9; . reflect (1) (1) route (1)
66:14 72:7 92:9 92:12 55:15
pursuant (1) realize (1) refused (7) reserves 2) routinely (1)
92:11 74:15 38:5,8;40:25;41:5, 73:25
pursuing (1) really (11) 11;61:20;79:20 resigned

rule (3)
. 69:8 9:21;11:9;12:16; refuses (1) 9:5 31:21;49:19;93:4
pushed (1) 26:11;28:17;30:7; 82:23 resolved 2) Rules (5)
59:18 73:3;74: 14;83:5,24; refusing (2) 27:16;: 7:2 49: 19,21,22;80:22;
put (10) 88:24 44:2;83:13 resource

93:5
24:17;32:1;35:8; reason (6) regarding (1) 56:21 ruling (8)
48:10;49:7;64:8; 7:17;14:11;29:25; 35:2 respect ( ) 12:3,8;46: 19;
70:25-;81:16;82:13;- . .. 64:3;79:15;81:4 regret (1) . - 85:17 47:12,1-3;55:23;

83:11 reasonable (3) 59:1 respond 1) 56;10;62:18
putting (2) 21:6;30:14;51:19 regular (1) 48:1 rulings (3)
46:24;60:5 reasoning (1) 63:6 responde d (1) 13:8;56: 17;89:21
46:23 re-invests (1) 65:7 run (1)
Q reasons (1) 31:9 response (4) '8:23
74:2 related (1) 24:5;5t :23;61:4;
quick (2) recall (1) 68:16 90:2 S
25:17;35:9 53:11 relationship (1) rest (1) .
Quite (1) receive (1) 30:15 44:23 safety (1)
)Vi in-U-Script Reporters Inc. (9) proceedings - safety
(225) 216-2036
JOYCE NANlNE MCCOOL
March 20,2012
INRE: JC YCE NANINE MCCOOL
28469
T
tabbed '(1)":-- , .
67:1
tactic (1)
56:25
talk (9)
4: 1,6,20;9:24;
16:15;20:21;47:7;
65:21;93:12
talked (7)
4:2,3;34:20;66: 14
subjecting (1)
17:14
submitted (3)
39:23;45:8;75:24
subpoena (1)
92:12
successful (2)
57:9,13
suddenly (1)
31:8
suggest (2)
38:12;41:11
summary (2)
64:4;86:12
summer (2)
23:23,25
support (7)
21:6,21;30:3,12,
13;73:4;81:16
supported (1)
21:16
supposed (1)
83:16
Supreme (10)
27:6;39:23;45:8,
18;46: 13;56:2;59:11,
21;60:1;89:8
Sure (24)
6:5;7:22;18:8;
20:2,4;22:9;28:20;
34:25;35:5;37: 11;
47:3,22;49: 15;52:24;
53:2;54:1;70:8;
71: 17;74:22,24;
79:22;81:7;85: 1;
91:20
surprised (1)
50:16
switch (1)
20:20
SWORN (3)
3:5;92: 18;93:7
symbol (1)
69:24
system (19)
13:5;28: 16;30:24;
55:22;73:13,16;
78: 10;89:13, 14,19,
21;90:3,6,6,14,14,21;
91:5,10
spontaneous (1)
93:10
St(3)
44:2;46:6;81:1
Staff (1)
46:9
stamps (1)
81:11
stand (2)
60:21;91:1
standing (4)
58:7,8;63:20;
91:13
standpoint (1)
89:10
started (6)
8:12;9:11;24:15;
36:20;69:21;88:24
state (5)
7:20;14:16;35:3;
93:3,8
statement (4)
16:17;40:20;
41:10;92:18
states (3)
8:6;10:15;90:23
status (1)
11:23
stay (2)
29:21;85:19
stayed (3)
24:22;26:1;27:10
step (1)
53:20
step- (1)
30:4
step-children (1)
21:10
step-parent (1)
21:8
still (9)
4:4;9:9;27:9;
30:23;55: 18;63:20;
69:8;74:6;76: 1
stop (3)
17:1;34:18;64:9
stored (1)
70:11
Storm (1)
8:22
story (1)
14:13
Street (2)
3:3;8:1
strictly (1)
63:7
strong (1)
58:4
strongly (2)
50:22;51: 10
struggling (1)
21:22
stuff (4)
skills (1)
33:8
slash (1)
56:16
Smallwood (1)
16:9
Smith (3)
11:1,13,25
soap (1)
51:6
so-called (1)
62:14
social (13)
3:23;32:21;56:16;
57:2,19;73:5,24;
75:25;76:9;79:11;
84:23;89:23;90:18
society (1)
90:12
softball (1)
88:5
(1)
60:5
somebody (1)
69:17
somehow (3)
51:9;60: 17;71:3
someone (10)
30:10;35:22;50:7;
70:10,22;71:11,24;
72:1;77:22;82:19
somewhat (1)'
54:6
sorry (2)
28:10;85:24
sort (4)
28:10;50:12;
68:14,22
sought (2)
10:18;89:5
. sound (2)
70: 14;79:21
sounds (5)
9:16;10:10;38:18;
51:19;72:19
space (1)
7:11
speak (3)
11:12;59:19;60:22
speaking (4)
35:22;62:2;76: 11;
85:5
specific (7)
18:4;59:3;69:16;
84:24;85:4,11,12
specifically (2)
5:8;78:9
speculation (2)
18:6;53:23
speed (1)
63:23
spoke (1)
82:2
23:11;25:9;26:4,
10;33:16
serious (3)
35:1;58:1;89:2
serve (1)
64:19
served (6)
31:7;58:3;62:25;
64: 16;65:2;91:14
service (1)
9:1
services (1) .
18:2
session (2)
28:11,18
set (11)
6:23;22:12;32:3;
33:19;35:11;55:22;
81:18;84:5;89:21;
. 90:3,3
several (1)
35:14
sexual (7)
11:9,16;18:22;
24:4;37:3,6;73: 15
shake (1)
91:9
shall (1)
19:7
shape (1)
58:24 .
share (2)
7:10;50:23
shit (2)
83:16,18
short (2)
58:15;63:13
shortly (2)
54:24;55:2
Show (1)
72:22
sign (3)
44:17;52:7;81:17
signatures (3)
52:12,15;73:4
signed (1)
52:17
similar (3)
17:9,16;18:22
Simon (1)
46:10
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JOYCE NANlNE MCCO'OL
28469
March 20, 2012
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T\lhl-U-SCrlpt AssoaalJ4 Reporters Inc. (11) talking - word
(225) 216-2036
JOYCE NANINE MCCOOL
March 20, 2012
86:9;87:7;89:16
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Associated
(225)
INRE: J( YCE NANINE MCCOOL
28469
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2012-03-20 Depo of McCool

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DISCIPLINARY BOARD 0 THE

LOUISIANA' STATE BAR ASSOCIATION

ASSOCIATED REPORTERS, INC.

actually represent her but I

Orleans Street, Mandeville, 70448.

ASSOCIATED REPORTERS, fNC.

ASSOCIATED REPORTERS, lNC.

. exercise their parental right 3 of

Judicial District Court for the Parish of

Did I curse on Twit1 er? I was

A. Could have been.

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