File: LVCrt-07
Superior Court of the State of California
City and County of San Francisco
Number 891863
Diane Hegarty, Plaintiff
vs.
Anton LaVey et al., Defendants
DECLARATION OF ZEENA LaVEY IN OPPOSITION TO DEFENDANT'S MOTION
TO
SET ASIDE DEFAULT AND STAY OF JUDGMENT PENDING DETERMINATION
1. I am the daughter of plaintiff Diane Hegarty and defendant
Anton
LaVey.
2. In 1974 my mother explained to me that my father had a
heart
murmur in addition to the hypertension we already knew about. For
several years my mother, my sister Karla, and I had all made
ourselves available to monitor his blood pressure, using a
standard
cuff and meter. Sometimes defendant had me perform this task 3-5
times in a half-hour period. Defendant would then take the
highest
reading as proof he could not participate in any deadline or
family
responsibility.
3. Defendant LaVey often developed other sudde illnesses, such
as
headaches, flu, or dizziness. These symptoms usually occurred
shortly before a long-planned appointment or commitment, causing
him
to cancel his participation. If I mentioned having a cold, he
always
had worse symptoms than mine.
4. Since my mother filed this action, I have frequently heard
defendant LaVey express his utter contempt for all aspects of the
case. He consistently refused to get a lawyer, expressing the
belief
that if he refused to participate, "the idiots would get
tired of
their little game and just give up".
5. Defendant LaVey has left me in no doubt that he did not
intend to
participate in the lawsuit, although he was aware at all times
what
was being asked of him. His health was not the issue except when
it
was useful. He simply wanted to punish my mother for leaving him
by
depriving her of everything she had worked to obtain during the
time
they lived together.
I declare under penalty of perjury that the foregoing is true
and
correct.
Executed this 27th day of August 1991 at Vienna, Austria:
/s/ Zeena (nee LaVey)