Direct Exam Robin Simon
1. What is your name? PG 59 Line 1
2 .Who are you to Zach Simon? PG 59 Line 4-5
3 .How old was Zach? PG 59 line 3-4
4 .Explain your relationship with Zach? PG 59 Line 5-7
6 .When did you notice a change in Zach? PG 59 Line 11-13
7 .Where did Zach get his Addiction problems from? PG 60 Line 65-66
8 .Explain the solution you came up with? PG 59 Line 42-45
9 .What was Zach’s Morality? PG 60 Line 60-63
10. Elaborate on When you say “picked it up from me”? PG 59 Line 50-53
11. What is your occupation? PG 60 lines 54-56
12 .Who would take care of Zach? PG 60 Line 57-58
13 .How do you know Francis Martin? PG 60 Line 72-75
14 .What do you mean by “ first class Liar”? PG 60 Line 75-78
15 .Why you choose to confront frances? PG 60 Line 82-85
16 .What happened next? PG 60 line 89-90
17 .Describe your feud with Frances? PG 60 line 90-92
18 .How do you Know Dana Martin? PG 60 line 68-70
19.What happened after the encounter with Frances Martin?
I had it out on the phone with Frances for doing that, when what I did was just an accident; calling 911, on the other hand, was on purpose. It ended with Frances telling me never to call him/her again. (p. 61, L108-110)
20. Was that the end of your relationship with Mr. Martin?
Fast forward a few years, I swallow my pride and went to the thieving, good-for-nothing’s house to apologized to him. (p. 61, L115-116)
21. Why did you go apologize to Frances after all that time?
I was deep in my Alcoholics Anonymous phase. I get to “Step Nine: Make direct amends to any people we have harmed wherever possible, except when to do so would injure them or others.” (p. 61, L112-114)
22. What happened when you went to Frances house?
Frances let me in.( p. 61, L118)
23. Where you and Frances alone at his house?
His boy/girl, Dana, s/he’s there. (p. 61, L118)
24. Did Dana say anything to you during your visit?
I was making my amends, pouring my heart out, and who speaks up but Dana, that snotnosed kid. Dana, who must have been about 15 at the time, had been too young to remember all the things I had done to Frances. But Dana says, “my grandpa/ma is better off without you! You were always a mean drunk!” (p. 118-122)
25. Did you respond to Dana’s comment?
I stuck up for myself, told the boy/girl how dear grandpa/ma had stiffed 123 me for five grand.(p. 61,L 122-123)
26. Where was Frances during your Dana conversation?
Frances, s/he gots physical with me. Then, Frances threatens to call the cops, says s/he’ll tell police I forced my way into their house. (p. 61, L123- 124)
27. What was your response to France’s comment?
I just left. I decided that, if anything, that old gambler/cheat should make amends with me for injuring my pocketbook. I won’t hold my breath for that though! (p. 61, L125-126)
28. Is this normal in your relationship with Frances?
I know Frances well enough to know that s/he is a capital-L “Liar” and S/he is dishonest. (P. 61, L128)
29. Is Frances known to be a liar and dishonest?
That’s his/her reputation all over the neighborhood. Everybody’s always known, when Frances Martin needs to “borrow” some money, or claims s/he has some business arrangement for you, you should walk the other way.(p.61, 129-131)
30. How else do you know Dana Martin?
Dana is certainly a chip off the old block. Dana cut my nandinas to a stomps from a strip mall contract I had to put I strubs.( p. 61, L133-137)
31. Did you press charges on Dana Martin?
I demanded to the prosecutor that Martin the younger and his/her partner in crime pay back every penny of that as restitution. It was ordered by the court, but neither one has paid a dime yet! (P. 61, L141-143)
32.What do you know about your sons and Dana’s relationship?
Dana tried to get close to Zach since they started going to the same school in middle school, though Zach, being smarter, was a grade ahead of Dana. I had always discouraged it, since that four flushing Frances Martin had already cheated me by then.
(P. 61, L143- 146)
33. Did confront Zach about their relationship?
I went to Zach at the time and asked: “I know that I told you never to see Frances’ grandkid, but be straight with me- are you friends with him/her?” Zach admitted he was, but swore to me on his mother’s/father’s grave that he’d never have anything to do with him/her again. ( P. 61, L148-151)
34. Is that the last time you saw Dana and Zach together?
I caught Zach with Dana in the driveway, in that old jalopy pickup just a week before Zach was taken away from me. Zach explained that Dana was in Narcotics Anonymous, and Dana had given him a ride to a meeting. They both looked high as a kite! I can tell when people are using heroin. Pinpoint (constricted) pupils, slurred speech, the both of them!
(P. 61,L 151-155)
35. What's zach’s drug history?
Zach’s last treatment was a one week detox in Newark in April. He was to follow up at another program, but left against medical advice on Arbor Day, April 28, which otherwise would be my favorite day of the year. When I saw Zach in the driveway coming back from the program, it was in the Martin ratty-old pickup truck, with Dana at the wheel! ( P. 61, L157- 161)
36. What kind of kid was Zach?
Zach always wanted privacy in his room. He’d put on headphones, and listen to music in the dark. He’d hardly make a sound. So it wasn't strange when he had not answered my call for dinner that night. That was just Zach being Zach. (P.62, L167-169)
37. Why do you think Zach valued privacy in his room?
Zach used to escape out the bedroom window, back when he was much younger, and we’d ground him. A few months ago, the problem was someone delivering heroin to Zach in his room, by coming up to his window, Zach’s room being on the first floor.
(P.62, L171-173)
38. What do you consider you addiction status at this moment?
Now I’m stone cold sober again. Living addicted to anything is no life at all. Zach would have wanted me to live clean. ( P. 63, L216- 217)
Emma De Leon & Jerry Lara
Direct Exam Robin Simon
1. What’s your name? My name is Robin Simon (page 59 line 1).
2. What is your relationship with Zack Simon? Zack Simon is my son (page 59 lines 4-5).
3. What kind of behavior did Zack have as a child? Zack was a very loving son. He would shovel snow for my parents and me, take us to the doctors, take out the garbage and walk the dog. But he changed later on in his senior year of high school. (page 59 lines 5-6 and 11-12).
4. How old was Zack when he died? Zack was 21 years old when he died. (page 59 line 3)
5. Did Zack have any medical problems? Well, he was allergic to trees, grass to everything but air practically. (page 59 lines 8-9)
6. How many schools did your son attend? My son went to two different schools. At first, he went to Metropolitan high school but then we moved and to Harbor then he started going to Harbor high school. (page 59 line 17-20)
7. Can you please tell the court the reason you guys moved from Metropolitan to Harbor? I wanted him to move away from the drug 19 ridden Metropolitan high school. (page 59 lines 17-19)
8. How does your son know Dana Martin, can you tell the court how their relationship was like? Dana had tried to get close to Zack since they started going to the same school in middle school, though Zack, being smarter, was a grade ahead of Dana. I had always discouraged it since that four-flushing Frances Martin had already cheated me by then. I went to Zack at the time and asked:" I know that I told you never to see Frances' grandkid, but be straight with me are you friends with her?" Zack admitted was, but swore to me on his mother's grave that he'd never have anything to do with her again. Then, just a week before Zack was taken away from me, I caught Zack with Dana in the driveway, in that old jalopy pickup. Zack explained that Dana was in Narcotics Anonymous, and Dana had given him a ride to a meeting. Just a week before I found Zack unconscious body in his bedroom, I saw Dana leaving there. At some ungodly late hour, I heard talking coming from Zack's bedroom, which I couldn't quite make out the words. (pages 61-62 lines 144-153 and 177-179)
9. When you were aware that Zack was taking drugs what did you do? When I knew that Zack was taking drugs I spent Zack's college fund on rehabs, once I hit the insurance caps. The Florida one was a scam. They let Zack "uses" drugs, that is, and pocketed the insurance money. Then came the ones in Arizona and Maine, without insurances. (page 59 lines 42-46).
10. How did Zack get the money to buy drugs and do whatever he wants? Zack started to steal to get the money that he needed to buy drugs. Things started disappearing around the house and my parents' home, next door. my dad had a coin collection. Then my mom's cuckoo clock got legs and was gone. Zach would just deny everything, always. A friend spotted him at a pawn shop once, and hat led us to get my mother's jewelry back, including rings inscribed with her name. Zack was charged with stealing all those items. It broke our hearts when my mother pressed charges. But we all hoped that would help Zach. He did dry out in jail for a few days, and he did stay clean in inpatient rehab for some months thereafter.
No father questions sir