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Larry Parrish's redo of under oath -- it's called "reopen proof" in Tennessee


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Home > Judicial Misconduct & Cover up > Larry Parrish's redo of under oath -- it's called "reopen proof" in Tennessee

Larry Parrish's redo of under oath -- it's called "reopen proof" in Tennessee

elsewhere in the world, it's called perjury

Charge No. 11, Mr. Alissandratos colluded with Kim Mullins and Larry Parrish to falsify testimonies regarding the No Contact order

 

On March 1, 2004, Kim Mullins testified under oath regarding her involvement in this case. According to her sworn statements filed later with the court, she had studied all previous court transcripts to prepare for her under oath testimony. During her testimony, David Siegel cross-examined her with many questions asking her to provide her knowledge about the basis of the 2002/02/08 No Contact order (Transcript, Testimony of Kim Mullins, pages 81 to 89). Kim Mullins was able to recall the details of the February 7, 2002 hearing, but basically said "I don't know" regarding why and how the No Contact order was issued.

 

Then Mr. Siegel asked: "Ms. Mullins, as the guardian ad litem in this case, was it not important for you to determine how the No Contact order was issued?"

Ms. Kim Mullins answered: "I guess I didn't", she went on explaining her view on the visitation issue.


Mr. Siegel then asked: "All I'm asking you is just to respond to my question. Did you do anything at all to corroborate or conduct any investigation to determine why the No Contact order was issued, since we know you don't know why it was issued, my next question is, what did you do to investigate as the guardian ad litem for this child why a No Contact order would be issued?"

 

Ms. Mullins' under oath answer was: "I really don't know the answer. Sorry."

 

Then, Parrish cross-examined Kim Mullins. Parrish went through a lot of details, such as Jack He=s deposition, and his purchase of a Mazda car, etc. Then Parrish led to the Feb 7, 2002 hearing (Transcript, March 1, 2004, examination of Kim Mullins, pages 162C170). In particular, he questioned about the passport of Anna Mae, Kim Mullins provided in great detail the events around the passport, and the order requiring Hes to turn in the passport before 4:00 p.m. of Feb 7, 2002.  Kim Mullins talked about receiving a phone call from Mr. Sossaman informing her of the situation regarding passport.

 

Mr. Parrish: Did he advise the Court that that was not going to happen?

 

Kim Mullins: He first called you and me an on conference call and advised us, and then we all got on a conference call with Mr. Sossaman, you and I and Mr. Alissandratos wherein Mr. Sossaman advised the Chancellor that it was not going to be produced that day.

 

Mr. Parrish: And by the time court adjourned that day, there was a lot of milling around, a lot of press, and it was a sort of tumultuous for a courtroom, was it not?

 

Ms. Mullins: On the 7th?


Parrish: Yes.

 

Mullins: Yes, I think so.

 

Parrish: And as far as this No Contact order was concerned, you don=t have any memory of it until after it was put down B after the Chancellor signed it?

 

Mullins: No, I really don't.

 

(Transcript, March 1, 2004, examination of Kim Mullins, page 164-165)

 

From this, we can see that Ms. Mullins remembered perfectly the events around the passport, at about 4:00 p.m. She remembered perfectly about the conference call with Mr. Sossaman regarding the passport. And she testified she had no memory of the No Contact order until after Mr. Alissandratos signed it. Then Mr. Parrish led to the events at the end of the February 7, 2002 hearing, around noon time, implying that he knew something important happened then.

 

Parrish then went on to the Feb 14, 2002 show cause hearing, in great details.

 

Then, Richard Gordon, attorney for Mrs. He cross-examined Ms. Mullins and questioned again about the 2002/02/08 No Contact order.(transcript, Kim Mullins, page 171-).

 


On the very next day, on March 2, 2004, Parrish testified under oath regarding the 2002/02/08 No Contact order. As the person who wrote the order, Parrish testified that he knew exactly how the order came to be. Parrish provided vivid details on how Mr. Alissandratos and he stayed together alone immediately after the February 7, 2002 hearing to discuss the Guardianship and No Contact order and how the two of them made handwritten changes to it the next morning on 2002/02/08. Parrish also testified that Mr. Alissandratos told him not to get signatures of other lawyers. Parrish made sure in his testimony that the No Contact orders were Mr. Alissandratos's own orders, he was just a scribe.

 

So, we have this consistent story from Parrish. Mr. Alissandratos and Mr. Parrish entered the No Contact order in private without anyone else knowing the process. Therefore, Kim Mullins could not know how and why the No Contact order was issued; and, Dennis Sossaman did not know about the No Contact order in the night of February 7, 2002, when he informed the Hes about the Feb 14, 2002 show cause hearing regarding the passport.

 

Only Parrish and Mr. Alissandratos knew what happened in their private meeting after the court recess on February 7, 2002 and the meeting next morning. Mr. Parrish testified that Mr. Alissandratos and he did enter the No Contact order during those two behind closed door meetings.

 

Kim Mullins was not present when Mr. Alissandratos and Parrish met twice, alone by themselves. Kim Mullins could not have known what Mr. Alissandratos and Parrish talked or did not talk about.

 


Surprisingly,  16 days after Parrish's testimony, Kim Mullins filed a "Motion to re-open proof", she claimed that Parrish erred in his testimony, she basically said Mr. Alissandratos and Parrish did NOT discuss the No Contact order during the private meetings of Mr. Alissandratos and Parrish, instead,  she claimed that Mr. Alissandratos talked about the No Contact order after the private meeting between Mr. Alissandratos and Parrish, she wanted to show that Mr. Alissandratos talked about the No Contact order for the first time during a conference call in which Sossaman participated. How does she know?

 

In her affidavit, Kim Mullins wrote:

 

"On Thursday, March 18, 2004 while endeavoring to assist Mrs. Homles in working on the Findings of Fact and Conclusions of Law, requested by this Honorable Court, I contacted Mr. Larry Parrish with respect to his testimony given on the Guardianship and No Contact Order at trial, as I was concerned that there are portions of his testimony that were in error....

The circumstances now within my personal knowledge with respect to the issuance of the Guardianship and No Contact Order are as follows...Accordingly, it was during our phone conversation with Mr. Alissandratos that I reiterated my concerns on behalf of the child and, given that the Respondents were refusing to obey the Court's Order on the passport, asked for an order from the Chancey Court to protect the child. As a result Mr. Alissandratos stated that respondents were to have No Contact with the child whatsoever and reiterated that the court wanted its own order of guardianship for the Baker's. The purpose of the No Contact order was for the protection of the child... To the extent that Mr. Parrish testimony given in this cause conflicts with the statements made herein, the Guardian Ad Litem would state that such testimony of Mr. Parrish is incorrect."

 


The above were the bold words of Ms. Mullins. She reversed her under oath testimony from not being involved in the No Contact Order at all to being the person who requested the No Contact Order. During testimony, she remembered perfectly well about the conference call with Sossaman, Parrish and Mr. Alissandratos, and she maintained she knew nothing about the No Contact order until after it was signed. Even more incredibly, she claimed that Parrish's testimony regarding the private meeting between him and Mr. Alissandratos prior to the conference call was erroneous.

 

Does Kim Mullins have taping recordings of all Mr. Alissandratos and Parrish=s private discussions of the No Contact order? We can safely say the answer to this question is NO.

 

Parrish quickly responded to Kim Mullins' motion and motioned to redo his under oath testimony, he also came up some phone notes for the February 7, 2002 conference call regarding the passport. According to the alleged phone notes, Kim Mullins requested orders, Mr. Alissandratos responded by granting Bakers guardianship and ordering zero contact with the child for the Hes.

 

Now we have two persons, Parrish and Mullins who are willing to change their under oath testimony, willing to admit perjury in their under oath testimony in Chancery Court to defend Mr. Alissandratos in the Court of Judiciary, but since these two people are admitting they perjured themselves in their under oath testimony in the Chancery Court, they should have no credibility in the Court of Judiciary either.

 

After getting Kim Mullins and Parrish's modified version of the story, Mr. Alissandratos, in his belated formal response to the court of judiciary, claimed he made the decision to issue the No Contact order during the conference call upon Kim Mullins' recommendation.

 


The close proximity between Ms. Mullins and Mr. Parrish's attempt to modify their under oath testimonies and Alissandratos' filing a response to the Court of Judiciary using these modified testimony indicates that there is a strong correlation between these two sets of events.

 

If we believed Ms. Mullins, Mr. Parrish and Mr. Alissandratos' newest theory, we would have a totally irreconcilable situation:

 

a)       According to the phone notes, Kim Mullins requested the order, but she testified under oath that she knew nothing about the No Contact order.

b)       Mr. Alissandratos claimed that Kim Mullins recommended the No Contact order. Mr. Alissandratos hand wrote "including the recommendations of GAL" on the 2002/02/08 order, but those words were in the context of the guardianship order, not for the No Contact order.

c)       Sossaman knew nothing about the No Contact order on February 7, 2002.

d)       Mr. Alissandratos claimed he did not remember the reason for No Contact order on March 7, 2002 (Transcript of March 7, 2002 hearing, page 4, L19), but now his memory comes back, and he claims that he issued the order because he considered the Hes a flight risk.

e)       The passport excuse cannot explain the content of the No Contact order. The order banned not only direct contact, but also indirect contact. Even if Mr. Alissandratos assumed that the Hes were a flight risk, since Anna Mae was only 3 years old and did not have the ability to see the Hes by herself, indirect contact between the Hes and Anna Mae, such as a message delivered by the guardian ad litem, could not possibly result in any risk.


f)        Parrish testified under oath that both the guardianship and the No Contact order were issued right after the hearing, in the private meeting between Mr. Alissandratos and himself, now he claims that the Guardianship order was issued in the private meeting, but the No Contact order was issued later during the conference call.

 

So if we believed what these people are saying now, we have totally inconsistent stories. Kim Mullins and Mr. Alissandratos said they did not remember how and why the No Contact order was issued, now they remembered, Parrish remembered about it perfectly during the trial, he gave colorful details of it, but now he changes his story after Kim Mullins asked him to do so. But Kim Mullins wasn't in that private meeting, so she is not qualified to say on what Mr. Alissandratos and Parrish talked about or did not talk about. There are now so many different versions of the same story. But the ones from under oath testimony were self-consistent, and the newly modified ones are full of inconsistencies. We should believe what these people testified under oath to be true. We must then consider the later feverish attempts to modify testimonies as an effort of collusion.

 

Now, based on reliable information, Parrish and Kim Mullins have been calling Sossaman to urge him to "remember" the "No Contact order". In his response to the Disciplinary Counsel, Mr. Sossaman wrote "It is getting to the point that I wish I had a dime for each person that asked me about the situation, I would be a rich man". Clearly, he was under a lot of pressure.

 


Parrish and Mullins could have gotten away with clean hands by sticking to their original testimony. Parrish knows a good rule of life, as he often says, when you are in a hole, stopping digging. But Parrish is violating his own Golden rule here. Apparently, Mr. Alissandratos was not happy with their under oath testimonies, and now we have Mr. Alissandratos, Parrish and Mullins working together very hard to create a new version that could make Mr. Alissandratos and themselves feel more comfortable. The missing link is Dennis Sossaman. The only possible explanation to this coordinated effort to whitewash Mr. Alissandratos's role in the ex parte No Contact order is that Mr. Alissandratos has exerted influence both Parrish and Mullins, so they latter two had to cover Mr. Alissandratos, even risking being charged for perjury. The risk for Parrish and Mullins not to cover Mr. Alissandratos must be greater than their risk of being charged as perjurers. These three people have bonded together, as they know if Mr. Alissandratos is brought to justice, none of the will be able to escape unscathed.

 

As we will show again and again, this case is full of conspiracies. This pattern of colluding testimony will manifest itself again when we press other charges.

 

Indeed, Mr. Alissandratos is a very powerful judge. As we will show later, he can also get Linda Homles to lie to cover his misconduct.

 

To help understand better this ex parte No Contact Order and the efforts by Mr. Alissandratos and Parrish to fix the story about it, we list the time line below:

 

February 7th, 2002, 10 to 11 am: There was a hearing regarding the motion to require the Hes to post deposit. Mr. Alissandratos ordered Hes to pay $15000 in a week. Kim Mullins brought up the issue with Anna Mae's passport with no written record filed, Mr. Alissandratos quickly ordered the Hes to turn in the passport by 4::00 p.m the same day. The Hes were in the Court but were not given a chance to say a word. This was the first time they met Mr. Alissandratos. The orders came from this hearing was signed on February 12, 2002.

 


February 7th, 2002, right after the hearing: After others left, Parrish and Mr. Alissandratos stayed in the court, and discussed the Guardianship and No Contact Order. This was according to Parrish's under oath testimony on March 2, 2004.

 

February 7th, 2002, 12:14 a.m.: Jack He and Casey Luo faxed a two page letter to Mr. Alissandratos, explaining the case and asked for the Court's fair judgment in deciding the case.

 

February 7th, 2002, afternoon: Jack He told Sossaman that he was willing to turn in the passport, but Casey Luo hid it somewhere, and did not want to give it up.

 

February 7th, 2002, around 4:00 p.m: Sossaman notified Kim Mullins and Parrish the situation regarding the passport, and then had a conference call with Mr. Alissandratos. Mr. Alissandratos issued the show cause order requiring the Hes to appear in Court on February 14, 2002.

 

February 7th, 2002, 4;18PM, Jack He faxed a letter to Sossaman, stating that they did not want to Ashow contempt for court orders@, he asked Sossaman to file a motion to delay the order to turn in passport until they get consultation from the immigration attorney regarding their rights.

 

February 7th, 2002, after the conference call: Sossaman wrote a two page letter to the Hes informing them of the show cause order. Sossaman pleaded them to turn in the passport before February 14, 2002, to give him an opportunity to win their daughter back. No reference to any No Contact order.

 


February 8th, 2002, morning: Parrish went to see Mr. Alissandratos alone regarding the Guardianship and No Contact order. Both made handwritten changes to it. The order was signed by Mr. Alissandratos and Mr. Parrish only and copies were sent to others.

 

February 14, 2002:  The Hes went to the court for the show cause order. Mr. Alissandratos held them in contempt of the court. No mentioning of Guardianship and No Contact order.

 

March 7, 2002: There was a court hearing regarding David Siegel's motion for immediate visitation. Mr. Alissandratos said he did not remember why he issued the No Contact order. Parrish said that Kim Mullins asked Mr. Alissandratos to do it and the Hes were there and did not object.

 

January 2004: The Court of judiciary asked Parrish to recall what precipitated the Guardianship and No Contact order.

 

March 1, 2004: Kim Mullins testified during cross-examination by David Siegel that she knew nothing about how and why the Guardianship and No Contact order came to be. In subsequent cross-examination by Larry Parrish, Kim Mullins recalled in great detail about the conference call with Sossaman, Parrish and Alissandratos regarding the passport on Feb 7, 2002, but Mullins denied any knowledge of the No Contact Order prior to it had become a record.

 

March 2, 2004, Parrish testified that the Guardianship and No Contact Order was issued by Mr. Alissandratos right after the hearing, in a private meeting between the two of them, he was only taking instructions from Mr. Alissandratos. Mr. Alissandratos asked him not to get other attorneys signatures.

 


March 18, 2004: Kim Mullins contacted Larry Parrish, saying that Parrish  March 2, 2004 testimony were incorrect. She claimed she then came to know that the Guardianship and No Contact order was issued during the February 7th, 2002, 4:00 p.m. conference call, after the private meeting between Mr. Parrish and Mr. Alissandratos.

 

March 19, 2004, Kim Mullins filed an affidavit, stating that Parrish's March 2, 2004 testimony was incorrect.

 

March 19, 2004: Parrish filed his response to Kim Mullins' motion to reopen proof. He claimed that the No Contact order was issued in the way Kim Mullins described, and the Guardianship order was issued during his private meetings with Mr. Alissandratos.

 

March 26, 2004: Mr. Alissandratos filed his response to the Court of Judiciary, Mr. Alissandratos included Kim Mullins' affidavit, and Mr. Alissandratos claimed that Kim Mullins recommended the No Contact order.

 

May 2004: Reliable information indicates that Parrish and Kim Mullins are urging Sossaman's to recall the No Contact order in the conference call.

 

 

 

 

04/21/2005, 08:56

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