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(NOTE: The following is a re-transcribed copy of the transcript of the May 17th, 2001 hearing for Martin Berg. It is not an official transcript and is not guaranteed to be correct in all details.)

SUPERIOR COURT OF CALIFORNIA

COUNTY OF NAPA

The HONORABLE W. SCOTT SNOWDEN, Judge

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THE PEOPLE OF THE STATE OF CALIFORNIA,


Plaintiff,


vs. No. CR103337


MARTIN PAUL BERG


Defendant.

___________________________________________)

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REPORTER'S TRANSCRIPT OF PROCEEDINGS HAD AT TIME OF REFERRAL FOR PC 1203.03 DIAGNOSTIC

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Napa, California

Thursday, May 17, 2001

1:30 O'Clock P.M.

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Reported By:

KAREN R. KRONQUEST, RPR

CSR No. 7482

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KAREN R. KRONQUEST, CSR No. 7482

1111 Third Street, Room 230

Napa, California 94559

(707) 253-4481, ext. 290
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A P P E A R A N C E S

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FOR THE PEOPLE: GARY A. LIEBERSTEIN

District Attorney
County of Napa
931 Parkway Mall
Napa, CA 94559

FOR THE DEFENDANT: MERVIN C. LERNHART, JR.

Attorney at Law
845 Jefferson Street
Napa, California 94559
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THURSDAY, MAY 17, 2001 1:30 O'CLOCK P.M.
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The above-entitled cause came regularly this day for hearing before the Honorable W. SCOTT SNOWDEN, Judge.

GARY A. LIBERSTEIN, District Attorney, County of Napa, 931 Parkway Mall, Napa, California 94559, appeared as counsel on behalf of the People.

MERVIN C. LERNHART, JR., Attorney at Law, 845 Jefferson Street, Napa, California 94559, appeared as counsel on behalf of the Defendant.

The HONORABLE W. SCOTT SNOWDEN, Judge.

KAREN R. KRONQUEST, RPR, CSR No. 7482, Official Shorthand Reporter for the County of Napa was duly present and acting.

The following proceedings were then and there had and taken, to wit:


P R O C E E D I N G S

THE COURT: People versus Berg. The defendant is present, both counsel are here.

One thing I want to make of -- well, first of all, I've received and read the Probation report and I think that what's gonna happen this afternoon, unless somebody has something I don't know about, is gonna be pretty perfunctory.

But I do want to say I've been getting a lot of correspondence directed to the Court and it is, of course, improper for a Court to receive such correspondence. And I understand the passion with which people view certain sorts of cases and the passion with which people view this case, but receiving such correspondence puts the Court in a big -- puts me, as a judge, in a very difficult position. And what I'm gonna do is direct that copies of the correspondence be provided to both counsel.

And I'm going to ask the District Attorney because most of these letters seem to support his end of the table as opposed to the Defense end of the table, I'm going to ask you to respond to each of them, if you would, on behalf of the court, Mr. Lieberstein. And perhaps you will be able to explain to these well-meaning people that it's simply not appropriate for me to receive or read requests from nonparties to an action as to how the Court should carry out its functions.

I'm not saying anybody has done anything wrong by making the effort, but I need to make it clear that it's not proper for me to read or consider such correspondence.

Someone has a hand up and I'm afraid, I -- not being a party to the action, I can't have -- I can't hear from you.

MR. MOYER: But I just wanted to ask a question about the law in general.

MR. LIEBERSTEIN: I can talk to you afterwards.

THE COURT: Okay.

The District Attorney will talk to you after court's over.

MR. MOYER: Thank you.

MR. LIEBERSTEIN: Your Honor, is it appropriate, if someone was going to address such a letter should address it to the Probation Department in making a recommendation; as I understand Probation receives letters and makes copies for both counsel when they are in favor of the People's position or in favor of the Defendant's.

THE COURT: Well, certainly a person can send a letter to the Probation Department if they want to and what the Probation Department does with it, I won't presume to opine on. However, it would not surprise me to hear Defense counsel saying the law is pretty specific on what the Court can take into consideration, and in fact what the -- what kinds of communications can be addressed to the Court. And the answer is legally filed briefs, legally appropriate arguments and victim impact statements and that's pretty much it, in addition to Probation reports and other official reports.

MR. LERNHART: Your Honor, I don't -- I can't give the Court the code section numbers, but my understanding of the law is that the law relating to the -- to sentencing and Probation reports permits certain input in the form of letters to the Probation officer relating to victims and victims' relatives. But I don't believe that it would permit the Court to consider -- maybe which is what you just got through saying, but I don't think it would permit the Court to consider letters sent to the Probation officer as proper input for sentencing.

THE COURT: That is what I just said.

MR. LERNHART: And what I would ask that -- I would object -- I think it would be inappropriate for the public, whatever their view is, whether it would support a particular view in sentencing and that might favor the defendant or might favor the Prosecution to in effect lobby the Probation officer with their -- what they view as the proper disposition.

THE COURT: Well, that may be the case, but I don't think the Court -- I don't think I as a judge can be telling people that they can't write letters to anybody. I can tell them that if they write a letter to me I can't properly read it and that it would be improper, that it -- that it would be improper for me to read it and I can't take its contents into consideration in judging a case, but I don't want to go beyond that to purport to curtail what somebody in a free society can do with his or her stationary.

MR. LIEBERSTEIN: I think the ultimate -- and I was just seeking some clarification from the Court. Ultimately the Court is going to hear legal arguments from counsel at the time of sentencing and if either counsel makes an inappropriate argument and the proper objection is made, the Court will rule on that. The Court will look at recommendations of Probation that will include recommendation from California Department of Corrections following return from a 1203.03 that the Court is going to pronounce today.

MR. LERNHART: Your Honor, I --

MR. LIEBERSTEIN: And any briefs that either counsel file. So I think -- I agree, I don't know how we can control letters written to who they're written to, certainly if letters are written to myself I'm going to take whatever legal position of advocacy that I believe is appropriate in writing this case and that would be based on all the factors of this case and what I deem to be appropriate at the time of sentencing.

So I -- I understand the public interest in this case as well and I just -- I guess what I'm saying for the record is I think Mr. Lernhart's been practicing law longer than I have and this Court certainly has, and we know that the factors that this Court considers at the time of sentencing will be those that are legal and appropriate.

MR. LERNHART: Your Honor, I'm -- I agree in principle about what Mr. Lieberstein just said. However, I think -- I don't think it appropriate that a Probation officer receive letters from third parties. The Probation officer's recommendation is an important component that the Court considers in sentencing. And while I have -- I believe and have faith in our Probation officers to put aside as best as possible to do so unsolicited letters, nevertheless, it sometimes is difficult to put aside something once you've read it.

I'm wondering if it would be appropriate for letters that were sent to Probation to be held until after sentencing rather than to give them to the Probation officer preparing the report. And I would -- I don't know it's appropriate to make such a motion at this time because Probation isn't here, but I really do have -- I've seen -- there's been a large number of letters and e-mails and correspondence from local people, from people as far away as the east coast, Canada, and some of these letters appear to be similar in the sense that they may represent some sort of concerted effort by interested groups. I don't believe that those are the sorts of things that a Probation officer ought to be subjected to for the reasons I've just said.

THE COURT: There's another thing I need to -- we haven't finished the first part of the discussion, but let me respond to that and then I'll finish the first part of the discussion, because there's another thing I -- another sort of two things I need to tell you. The first -- but in response to that, that may be the case, but I don't think pronouncements by me from where I'm pronouncing are a way to deal with it.

In other words, I don't think a judge ought to be telling a Probation Department what mail it can read or not read. I think it would be that a judge would rule on a request that a Probation officer's report be disqualified on the basis that it had been unduly affected by political lobbying and a request that another Probation report be prepared by somebody who hadn't been subjected to that political lobbying. I could rule on that. Whether I'd grant it or deny it, I have no idea. But I don't think for me to say something here and now, much less make orders here and now is appropriate. But I'd be willing to hear more.

MR. LERNHART: I agree. I don't think -- for one thing, I think Probation would have to be here. But I -- if the Prosecution was suggesting that letters be sent to Probation rather than to the Court, if that was what Mr. Lieberstein was thinking of when he mentioned Probation, I have the concerns that I've just generally stated.

MR. LIEBERSTEIN: I was thinking out loud, your Honor, about answering all the letters by myself. The source of my comment could have been the Court saying I would be responding to every single one, so I may have been looking for options.

THE COURT: You may decline to do that. I may put together a simple letter saying that it's not proper for a court to read or consider ex parte communications about a case and thank the writer for taking the trouble to write and apologizing for the fact that I can't be of more service or something like that. And that's fine. If that's the way it should be.

MR. LIEBERSTEIN: I certainly was not suggesting to Mr. Lernhart or the Court the court recommend something that would be deemed legally improper.

THE COURT: Among those letters, as I was -- I didn't read them, but I flipped through them. I saw two things that need to be mentioned to you. One came from an organization in St. Helena which operates a shelter that my wife and I have had -- I don't know whether you want to call it adopting animals business dealings, but that kind of relationship with. And I have on one -- it's an organization called "We Care." And I have on one occasion gone to a fundraiser, fund raising auction event for this organization and I believe a couple of years ago I sent them a check at Christmas time for some modest amount of a contribution.

Secondly, one of the letters came from a person I know fairly well who lives in St. Helena and is the wife of an even older friend of mine. A woman named Betsy Holzhauer.

Now I'm not subjectively concerned about whether either of those -- about either of those things having happened as far as my own view of my ability to impartially judge the case. I'm not worried about being affected by either of those things myself. But I clearly think it's something that ought to be disclosed to the two of you. Underscoring again the reasons why people -- it's unfortunate that people don't know how improper it is to write letters to judges that are hearing cases.

MR. LERNHART: Your Honor, I understand that the Court is going to direct that the letters the Court has received be provided to counsel.

THE COURT: Correct.

MR. LERNHART: And I assume that that would include the two letters the Court has just referred to.

THE COURT: There were two letters on the letterhead of the organization -- of the We Care organization. So there would be three: One from Ms. Holzhauer and two on the letterhead of the We Care organization. So but -- so the answer to your question is yes, but there are actually three such letters.

MR. LERNHART: Your honor, I'm --I've had many dealings with this Court and I have the utmost respect for the Court's ability to be fair and impartial. However, I would ask to reserve any response to the Court's disclosures until after I've had an opportunity to review the letters. All the letters, including the letters from the persons that the Court has -- or the organization the Court has referred to.

THE COURT: Entirely acceptable, and you'll want to talk to your client about it as well.

MR. LERNHART: That's correct, your Honor.

THE COURT: My question, then, would be whether you wish to continue this matter just so that that inquiry can go forward or whether you wish to proceed with the rather perfunctory task that the Court was going to have undertaken today, had these other matters not arisen.

MR. LERNHART: Your Honor, I would ask that the record reflect that defendant reserves whatever right he would have to object or take some sort of legal action in regard to the information in the letters and the Court's disclosure, and with the understanding that that is reserved, the defendant -- I would prepared to go ahead today with the referral to -- the 1203.03 referral.

THE COURT: That's fine. And entirely acceptable.

MR. LIEBERSTEIN: The People likewise, your honor, would like to proceed. I, too, have practiced for almost 16 years in front of this Court and am comfortable the People will receive a fair and impartial hearing from this Court.

THE COURT: Thank you.

Then going to the matter before the Court, I have received the Probation officer's recommendation and report and have read it. The recommendation is in accordance with the understandings that were reechoed at the time the plea was entered that before any sentencing occurs that the defendant would be referred to the Probation Department for a diagnosis and evaluation for a period not to exceed 90 days pursuant to the provisions of Penal code section 1203.03. And unless either counsel has any other matter you would like to raise, I'm prepared to do that.

MR. LIEBERSTEIN: Just to correct a misstatement, your honor, referral to the Department of Corrections, rather than the Probation Department for 1203.03.

THE COURT: Oh, did I say that? State Department of Corrections -- the defendant is to be referred to the State Department of Corrections for diagnosis and evaluation under section 1203.03 of the Penal code.

MR. LIEBERSTEIN: And I would concur that that's in accordance with the pleas reached on April 11th of this year before this Court and, quite frankly, very consistent with the Probation officer's recommendation and statements made in the Probation report.

I would ask the Court to the extent that you have the ability to request that the diagnostic center do a full diagnostic, which includes the full psychological background as well as the correctional counseling aspect.

THE COURT: I was going to ask you that. I don't do a lot of criminal calendar these days and there was a time when a Court's request for psychological evaluation had at least some impact as to whether such was performed. Is that --

MR. LERNHART: Your Honor, I would join in that request and I think the Court's request would have impact, and I notice that some of the more recent reports that I've seen sometimes either have a minimum or I think even in some instances no psychological evaluation, so I would join in that request.

THE COURT: I will direct that the transmittal to the Department of Corrections include a request from the Court for inclusion of a psychological evaluation as a part of 1203.03 report.

Then unless either counsel has anything else, I do hereby suspend proceedings under section 1203. You have a look on your face before I say that.

MR. LERNHART: Your Honor, I received this report -- there's no objection to the timing of the report. I received the report yesterday or the day before, but I did file under a separate letterhead a psychological evaluation requesting that it accompany the Probation report and other material along with the -- for the 1203 evaluation. And the Court doesn't have its file right before it, but that's in the Court's file and should be there and I would ask that that go to CDC along with the Probation report.

MR. LIEBERSTEIN: I know of no legal objection at this point, your Honor. I have reviewed the full study and I would not render an objection at this point.

THE COURT: That's not an uncommon procedure under circumstances like this. So you're -- it was Dr --

MR. LERNHART: Podboy.

THE COURT: Dr. Podboy? You're asking that Dr. Podboy's report accompany the transmittal materials to the Department of Corrections?

MR. LERNHART: That's correct, your Honor.

THE COURT: I will grant that request.

Section 1203.03 of the Penal Code, then, is hereby invoked and the case is suspended pursuant to the provisions of that section and the defendant is remanded to the custody of the Department of Corrections of the State of California for diagnosis and evaluation for a period not to exceed 90 days.

The matter will be taken off calendar and will be restored to calendar upon the defendant's return from the Department of Corrections at which time what will happen is that the matter is then re-referred to the Probation Department. The Probation Department reviews the report that the Department of Corrections files with the Court and makes a supplemental sentencing recommendation to the Court and then the matter comes back into court for imposition of sentence.

MR. LIEBERSTEIN: Your Honor, the defendant's no bail status would appear to remain with his remand and be in effect when he was return to Napa County subject to further court proceedings?

THE COURT: I had not remembered exactly what his custodial status was. He is currently being held without bail?

MR. LIEBERSTEIN: He is.

THE COURT: That will continue to be the status.

MR. LIEBERSTEIN: Thank you, your Honor.

THE COURT: Okay.

Then I don't know what the date will be, because we don't know how long the defendant will actually be at the Department of Corrections. The law only provides that is not to be more than 90 days. So sometime in the next few months the defendant will return to court and the matter be re-referred to Probation at that time.

MR. LIEBERSTEIN: Thank you, your Honor.

MR. LERNHART: Thank you, your Honor.

THE COURT: Thank you.

(The proceedings were concluded.)

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