NANINE MCCOOL

JLttorney at Law
March 29,2012
HON. Dawn Amacker
22nd JDC for the Parish of St. Tammany
P.O. Box 1090
Covington, LA 70434
Dear Judge Amacker,
RE: Elizabeth Varley Keister v. Robert Scott Keister
No. 2010-14558, c/w 2011-11491; 22nd JDC; Div. "L'
Compliance hearing set for April 24
On Tuesday, I mistakenly said during the hearingthat I would be available for the
compliancehearingin the Keister matter on April 24,2011, because I was already scheduledto
be at the courthouse on another matter. In fact, that Hearing OfficerConference on my calendar
for the 24th of April is scheduled inthe 24th JDC, and I am, therefore, unavailable for the
compliance hearing in your courtroom. I apologize for the inconvenience; I was distracted and,
admittedly, upset.
However, as I began to say onTuesday, neither I nor my client, seeany value to returning
onanother compliance hearing in this matter. Ms. Keister is either going to provide the still
outstanding discovery, and wewill moveforward, or she will not. If she doesn't, especially after
thelast two court appearances withMs. Ramirez, I amunwilling to yet again commitanentire
day, for which I must bill my client, tobe called names, physically threatened, and verbally
harangued by Ms. Ramirez, and then publically chastised bythe Court infront of peers and
members ofthepublic for conduct that was notmy own, but would appear otherwise tothose
present in the courtroom.
I also want to make clear, since I was not allowed to respond to Your Honor on Tuesday,
that I have absolutelyno personal animositytoward Elisabeth Ramirez. I do not know her
personally and, unless I'mworking on the Keister file, she does not occupy any part ofmydaily
concerns. Furthermore, I do not bear her any professional animosity; I simply dread having to
interact with her. While I have onoccasion become impatient with Ms. Ramirez's behavior, I
have never treated her other than professionally and have, just as I do inall my cases, extended
every courtesy and accommodation she has asked for when it was possible and appropriate for
me to do so.
I have submitted this letter tothe Clerk of Court for filing inthe record and provided a
copyto Ms. Ramirez so as not to engage in ex parte communication. While I would have
preferred torespond incourt, onthe record, since Your Honor would not allow metodo so, I
feel I have noother recourse than to do soby correspondence.
Physical Address: 1772 Orleana St. Mandevflle, LA 70448 ••Office: 985-624-7664 "Fax: 866-257-7742 •• Email: mccooIlega1<S)gmm1-,v,m March 29, 2012
Mailing Address: P. O. Box2638 Mandeville, Louisiana, 70470-2638 Page 1
Pleaseconsider any remaining issues with the motion to compel withdrawn.
Accordingly, I will conclude that you see no reasonfor any of us to appear for another
compliance hearing.
JNM/ab
Cc: Robert Keister
Ms. Elisabeth Ramirez, Esq.
HON. Malise Prieto, Clerk of Court, 22nd JDC
Physical Address: 1772 Orleans St.Mandeville, LA 70448 •• Office: 985-624-7664 ••Fax866-257-7742 •• Email: mccooUegaKatgmaa.com March 29, 2011
MailingAddress:P. O. Box 2638Mandeville, Louisiana,70470-2638 Page 2