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HomeMy Public PortalAbout16-CV-81371 Depo - SWEETAPPLE, ROBERT A. (11_30_16)1 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA CASE NO.: 9:16-cv-81371-BB DENISE DE MARTINI, PLAINTIFF, v. TOWN OF GULF STREAM, WANTMAN GROUP, INC., RICHMAN GREER, P.A., GERALD F. RICHMAN, and ROBERT A. SWEETAPPLE, DEFENDANTS. -----------------------------x 101 NE Third Avenue Suite 1500 Ft. Lauderdale, Florida 33301 November 30, 2016 9:11 a.m. to 1:05 p.m. DEPOSITION OF ROBERT A. SWEETAPPLE Taken before Doreen Fox Krenchicki, Certified Court Reporter, Registered Professional Reporter, Certificate of Merit Reporter, Certified Realtime Reporter and Notary Public for the State of Florida at Large, pursuant to Notice of Taking Deposition filed in the above cause. 2 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 APPEARANCES 2 3 4 DANIEL DE SOUZA, ESQ., 5 of the firm of DE SOUZA LAW, P.A. 6 101 NE Third Avenue, Suite 1500 7 Ft. Lauderdale, FL 33301 8 on behalf of the Plaintiff 9 10 JEFFREY L. HOCHMAN, ESQ. 11 of the firm of JOHNSON, ANSELMO, 12 MURDOCH, BURKE, PIPER & HOCHMAN, P.A. 13 2455 E. Sunrise Boulevard, Suite 1000 14 Ft. Lauderdale, FL 33304 15 on behalf of the Defendant, 16 Town of Gulf Stream 17 18 ROBERT TACHER, ESQ. 19 of the firm of PETERSON BERNARD 20 707 S.E. Third Avenue, Suite 500 21 Ft. Lauderdale, FL 33316 22 on behalf of the Defendant, 23 Wantman Group, Inc. 24 25 3 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 APPEARANCES (Continued) 2 3 4 JORDAN S. COHEN, ESQ. 5 of the firm of WICKER, SMITH, O'HARA 6 MC COY & FORD, P.A. 7 Suntrust Center, Suite 1400 8 515 East Las Olas Boulevard 9 Ft. Lauderdale, FL 33301 10 on behalf of the Defendants, 11 RICHMAN GREER, P.A., and 12 GERALD F. RICHMAN 13 14 JOSHUA GOLDSTEIN, ESQ., 15 of the firm of COLE, SCOTT & KISSANE, P.A. 16 222 Lakeview Avenue, Suite 120 17 West Palm Beach, FL 33401 18 on behalf of the Defendant, 19 Robert A. Sweetapple 20 21 22 23 24 25 4 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 I N D E X 2 WITNESS PAGE 3 4 ROBERT SWEETAPPLE 5 EXAMINATION BY MR. DE SOUZA 6 6 EXAMINATION BY MR. COHEN 151 7 8 9 E X H I B I T S 10 11 NUMBER DESCRIPTION PAGE 12 Sweetapple-1 Notice of Taking Deposition 13 of the Corporate Representative of the Town of Gulf Stream 8 14 Sweetapple-2 Copy of Defendant Robert A. 15 Sweetapple's Response to Plaintiff's First Request for 16 Production 23 17 Sweetapple-3 Copy of Defendant Robert A. Sweetapple's Amended Response 18 to Plaintiff's First Request for Production, numbers 18, 19 22 through 25 23 20 Sweetapple-4 Plaintiff's First Amended Complaint 37 21 Sweetapple-5 Invoice from Sweetapple, 22 Broeker, Varkas, P.L. 73 23 Sweetapple-6 Copy of E-mail dated April 6, 2015 88 24 25 5 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 E X H I B I T S (Continued) 2 3 NUMBER DESCRIPTION PAGE 4 Sweetapple-7 Copy of Defendant Robert A. 5 Sweetapple's Rule 26 Disclosures 120 6 Sweetapple-8 Defendant Robert A. 7 Sweetapple's Response to Plaintiff's First Request for 8 Admissions 64 9 10 (Exhibits retained by Counsel) 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 R O B E R T S W E E T A P P L E, 2 HAVING BEEN DULY SWORN ACCORDING TO LAW, WAS 3 EXAMINED AND TESTIFIED AS FOLLOWS: 4 5 EXAMINATION BY 6 MR. DE SOUZA: 7 Q. Good morning, Mr. Sweetapple. 8 A. Good morning. How are you, Dan? 9 Q. I'm doing well. 10 A. Good. 11 Q. Can you tell me what your home 12 address is? 13 A. Sure. 14 333 Northeast Spanish Trail, Boca 15 Raton, Florida. 16 Q. Thank you. 17 We are here today in connection with 18 the case of Denise DeMartini versus Town of Gulf 19 Stream, et al, which includes you as a defendant. 20 Do you understand that to be true? 21 A. I understand that's the case I'm here 22 on. 23 Q. Okay. Now, you are here today 24 testifying both in your individual capacity as a 25 defendant and as a designee on certain topics on a 7 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 30(b)(6) deposition for the Town of Gulf Stream. 2 Do you understand that? 3 A. I've been told that. 4 Q. Okay. As to the 30(b)(6) deposition 5 for the Town of Gulf Stream, you understand which 6 topics you are testifying about today? 7 A. I do. I did review a schedule you 8 provided and I think I can identify those for you. 9 Q. Sure. 10 Why don't we introduce the Notice of 11 Taking Deposition of the Corporate Representative 12 of Town of Gulf Stream as Sweetapple-1 today. 13 A. It might be appropriate for 14 Mr. Hochman to designate on the record what I'm 15 being designated as. I can certainly do that from 16 my review but I think he's the one who's 17 designating my area of testimony. 18 MR. HOCHMAN: Let the record reflect 19 that the defendant Town of Gulf Stream did 20 file an objection to the notice that's the 21 subject of this deposition on October 19. 22 The objection covers deposition topics 1, 2, 23 3, 4, 6, 9, 10, 14 and 15. Those objections 24 are not being waived today. 25 Mr. Sweetapple has been designated to 8 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 discuss subject areas 7, 8, 11, 12 and 13. 2 (Whereupon Exhibit Sweetapple-1, 3 Notice of Taking Deposition of the Corporate 4 Representative of the Town of Gulf Stream, 5 was marked for Identification.) 6 THE WITNESS: Just so I can note my 7 copy, I think you said 7, 8... 8 MR. GOLDSTEIN: 11, 12 and 13. 9 BY MR. DE SOUZA: 10 Q. Mr. Sweetapple, I have handed you 11 what has been marked as Sweetapple Exhibit 1 and 12 it is a Notice of Taking Deposition of the 13 Corporate Representative of the Town of Gulf 14 Stream. 15 Have you ever seen this document 16 before? 17 A. Briefly. 18 Q. In preparation for your deposition 19 today, did you review these documents as to the 20 topics that you were designated to testify on? 21 A. Yes. 22 Q. Okay. And as Mr. Hochman stated, you 23 understand that you have been designated to 24 testify on behalf of the Town of Gulf Stream as to 25 topics 7, 8, 11, 12 and 13. Correct? 9 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. Yes. 2 Q. Do you understand that your answers 3 with respect to those topics would be as if Gulf 4 Stream were testifying itself? 5 A. That's my legal conclusion, based on 6 my legal training. 7 Q. Okay. Are you able, as you sit here 8 today, to provide testimony as to topic 7, which 9 is all facts and information known or reasonably 10 available to Gulf Stream that supported or 11 contradicted any allegations in the RICO complaint 12 concerning plaintiff? 13 A. I believe so. 14 Q. The same question as to topic 8 which 15 is, Gulf Stream's investigation, motivations and 16 reasoning for including plaintiff as a defendant 17 in the RICO lawsuit. 18 A. I believe so. 19 Q. Same question as to topic 11: All 20 meetings with information provided by Joel 21 Chandler that Gulf Stream relied upon in naming 22 plaintiff as a defendant in the RICO lawsuit. 23 A. I believe so. 24 Q. Same question as to topic 12: Public 25 records request received by Gulf Stream that were 10 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 purportedly sent and/or authorized to be sent by 2 plaintiff. 3 A. I believe so. 4 Q. Finally, same question as to 13: 5 Public records lawsuits received by Gulf Stream 6 that were purportedly sent and/or authorized to be 7 sent by plaintiff. 8 A. I believe so. 9 Q. You believe you are prepared to 10 testify today on behalf of Gulf Stream as to all 11 five of those topics, correct? 12 A. I do. 13 Q. Can you tell me what you did to 14 prepare, in your capacity as Gulf Stream's 15 designee, to testify on these five topics? 16 A. I reviewed the chronology that 17 Mr. Chandler provided me. I reviewed his 18 affidavit. 19 I reviewed certain documents that 20 were identified in the chronology that concerned 21 Ms. DeMartini. 22 I reviewed logs prepared by Gulf 23 Stream. 24 I reviewed my... let's see. I looked 25 through, generally, the files just to see if there 11 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 was anything that related to her, and there were, 2 you know, probably four or five Redweld's that I 3 went through, and I ended up seeing one of the 4 newspaper articles that I reread, and isolated 5 pleadings and other documents that I looked at. 6 What else did I see in the files I 7 was going through, that I read... I brought some 8 of them with me. If I went through them I'd 9 probably see some other things that I looked at. 10 I tried to hone in on the specific 11 areas that I was asked to testify about. So I did 12 go through as many files that I thought would have 13 information that was responsive. 14 Q. Okay. Other than reviewing files, 15 did you speak to anyone about preparing for this 16 deposition? 17 A. I spoke to Mr. Hochman by phone 18 yesterday. 19 Q. Okay. And was that for purposes of 20 discussing information as to these five topics? 21 A. He went over with me the areas that 22 he wanted to make sure that I did have information 23 about that I had, you know, gone back to look, and 24 I was certain that I had done a search of my files 25 and thought I was prepared to answer your 12 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 questions on those topics. 2 Q. Did you discuss with Mr. Hochman the 3 substance of any of those topics as opposed to 4 their existence? 5 A. I had previously discussed with 6 Mr. Hochman my involvement on behalf of Gulf 7 Stream as it related to other litigation you had 8 brought. So, it was pretty abbreviated because of 9 that. 10 He pretty much, I think, knows what I 11 know. He doesn't know everything I know about it, 12 but he has a general understanding and he did 13 discuss some broad-brush things that had occurred. 14 Q. Do you know if that conversation 15 focused on any particular area of these five 16 topics? 17 A. He went over each of the topics, just 18 to make sure -- but he didn't really say, on this 19 topic, this; or on that topic, that. 20 Q. And do you recall discussing the 21 substance of any particular topic such as -- 22 A. I remember -- I'm sorry. I didn't 23 mean to cut you off. 24 Q. In terms of the substance of any 25 particular topic, did you discuss that with 13 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Mr. Hochman? 2 A. I remember he... I think we talked 3 about the chronology, that I had a, basically like 4 cliff notes, when Mr. Chandler -- after 5 Mr. Chandler contacted me, which I really used in 6 order to debrief him, and that I compared to -- I 7 explained to him that I compared that to the 8 documents that he had provided me. 9 I went over the fact that you had 10 filed suit on behalf of CAFI to keep me from 11 releasing those to the client. Talked about his 12 affidavit, his sworn statement. 13 (Interruption.) 14 (Whereupon a discussion was held off 15 the record.) 16 THE WITNESS: I did discuss with him, 17 you know, that I had gone back and looked at 18 the affidavit. 19 In terms of specifics and documents, 20 I think that's pretty much what I told him 21 was the capstone of how I was refreshing my 22 recollection. 23 BY MR. DE SOUZA: 24 Q. Other than Mr. Hochman, did you speak 25 to anyone else about preparing for at least the 14 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Gulf Stream portion of this deposition? 2 A. No. 3 Q. Did you speak to Scott Morgan at all? 4 A. I told Mr. Morgan I was being 5 deposed. 6 Q. Did you -- 7 A. I didn't discuss my testimony with 8 him. 9 Q. That's what I was going to ask you. 10 A. No, I didn't. I did say to him that 11 I thought it would be beneficial for him to be at 12 my deposition, because he told me he was being 13 deposed. 14 Q. Did he have other things to do as 15 well today? 16 A. I'm sure. 17 Q. Any other members of the town 18 commission of Gulf Stream that you spoke to about 19 today's deposition? 20 A. No. 21 Q. Now, as to the documents that you 22 said you reviewed, one of the things you mentioned 23 was logs prepared by Gulf Stream. 24 A. Yes. 25 Q. Could you give me more information 15 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 about that? 2 A. Sure. 3 After the first barrage of public 4 records requests by Mr. O'Boyle and his entities, 5 which resulted in the town desiring to settle with 6 him so that this would stop, there ensued in I 7 believe the fall of 2015 another barrage of public 8 records requests, if you will, that began by 9 Mr. O'Hare, who the town believed was affiliated 10 or working in concert with Mr. O'Boyle and 11 Mr. O'Boyle's son. And the town, as I understand 12 it, was advised to start maintaining a log of all 13 of the activities that were occurring with regard 14 to public records requests that were made, in 15 terms of who made it, you know, how they responded 16 to it, what it was. And I've had access to that 17 log since I was retained. 18 So I did go back and review that log 19 for the time period prior to the RICO suit, which 20 I believe was February of '15. 21 And I also had a law clerk prepare an 22 analysis of the activities that were being engaged 23 in by Mr. O'Boyle, Mr. O'Hare, their entities, 24 alteregos and people they were affiliated with, 25 and I did review that as well. 16 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. As to the logs, I know you said 2 around fall of 2015 is when the Town of Gulf 3 Stream began preparing this log -- 4 A. That's my best recollection, yes. 5 Q. But you also said you reviewed the 6 log dating back to the RICO lawsuit which I think 7 was filed earlier than the fall of 2015 -- 8 A. I'm sorry. 2014 is when they started 9 keeping the log. And I reviewed it through -- I 10 just looked at it to see through February of '15. 11 And then I looked at, and I believe I 12 brought copies, of an analysis that our law clerk 13 prepared for me in 2000... I have to look and see 14 when they were prepared, but I think I had an 15 analysis through sometime in 2015 of those 16 activities. 17 Q. Do you know if that log was produced 18 by your counsel in this litigation? 19 A. I don't know. 20 Q. I'm sorry. The analysis. Not the 21 log. 22 A. I don't know. And I don't know that 23 it existed prior to the RICO case. I'm not sure. 24 I have to look and see when it was prepared. But 25 I went back and looked at it just to see if I 17 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 could see what was going on during that time 2 period from the analysis. 3 Q. Let's use that as a segue to talk 4 about documents. 5 You're aware that my client, Denise 6 DeMartini, served a request for production of 7 documents to you in this case, correct? 8 A. I'm aware I was served, I don't 9 recall what was in it, but I do recall there was 10 one. 11 Q. Are you aware that yesterday, through 12 counsel, you produced certain documents to me or 13 to my client? 14 A. I am aware based on my attorney's 15 communications with me that he produced some 16 documents to you. 17 Q. Is it safe to assume that you 18 provided documents to your attorney for purposes 19 of review as to whether they'd be produced to me? 20 A. It's safe to assume that I have 21 produced documents to my attorney in a number of 22 cases that you have brought either on behalf of 23 Mr. O'Boyle or CAFI, so I think he has -- I think 24 he already has a substantial number of documents. 25 I believe I may have produced documents that he 18 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 didn't have. I don't recall if he had them or 2 not, frankly. 3 Q. That's kind of what I'm asking. 4 In terms of what you provided to him 5 in the context of this specific case, do you 6 recall any specific documents that you provided to 7 your attorney? 8 A. I don't, because I think he worked 9 with my staff. 10 Asking me to locate a document would 11 be, you know, like asking me to use a computer in 12 a sophisticated manner. 13 There are probably 40 or 50 boxes of 14 documents and then obviously computer files 15 regarding over 40 cases and thousands and 16 thousands of public records requests. So he would 17 probably ask my paralegal or one of the associates 18 for an actual copy of a document. He might 19 interview me as to what exists or what I remember 20 existing, but I ask people for documents. I'm 21 sure you're the same way. 22 Q. Let me ask you; you said you 23 searched, for purposes of the Gulf Stream aspect 24 of this deposition, you searched through various 25 files and Redweld's to see what information 19 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 related or concerned the plaintiff, Denise 2 DeMartini? 3 A. What I did is I went through the 4 affidavit -- the documents I already had. I knew 5 that -- I knew the plaintiff was DeMartini and you 6 didn't want to hear about anybody else, so I went 7 through and reread documents I had and files to 8 just isolate and focus on her involvement so that 9 I would be familiar with it and I could answer 10 your questions more quickly without having to go 11 look at the document and then answer your 12 question. 13 The affidavit has -- recounts 14 dealings over probably a six month time period 15 when Mr. Chandler was working with Mr. O'Boyle and 16 then allegedly by the name of CAFI. Part of those 17 documents dealt with Ms. DeMartini. Part of the 18 e-mails that are referenced, I think I went back 19 and looked at some of the e-mails, for instance. 20 But I just focused on Denise 21 DeMartini. 22 Q. When did you do that review? 23 A. Monday night, Sunday evening. I had 24 done it when I was asked to do it. 25 Sometime ago I looked to see what I 20 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 had with DeMartini, had the office look, so those 2 were basically the same documents that they had 3 assembled in a stack. 4 Q. So relatively recently, you're saying 5 Sunday, Monday -- 6 A. The most recent time. But previously 7 I had looked at them, I think when the lawsuit was 8 served, at some point. 9 Q. As you sit here today, what documents 10 do you recall reviewing that actually referenced 11 DeMartini? I think you mentioned the Chandler 12 affidavit -- 13 A. His affidavit. I did not go back and 14 look at his statement. And I've never listened or 15 watched his video. But the affidavit, as I 16 recall, had much of the four and a half hour of 17 statements, not complete, so I looked at that. I 18 looked at the chronology he provided. I went back 19 where they were available and I looked at any of 20 the e-mails that were referenced in the 21 chronology, because the chronology is essentially 22 a chronology of the Dropbox you provided to me. 23 So I looked at the -- if there was DeMartini 24 saying, you're supposed to give me a hundred CAFI 25 lawsuits or you only gave me 20 or, you know, 21 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 anything where she was communicating, I tried to 2 go back and look at. 3 And I would read Mr. Chandler's 4 e-mails to her, for instance. 5 Pretty much, I pretty much focused on 6 the chronology, the affidavit and the documents 7 that were printed out that were in the Dropbox 8 that referred to her or that she was copied on. 9 Q. If I'm correct, today is November 10 30th. 11 A. It is. 12 Q. As of today, do you believe that you 13 have produced all the responsive documents that 14 you agreed to produce in connection with 15 Ms. DeMartini's document requests? 16 A. I haven't even analyzed that. I 17 believe that my office has worked in good faith 18 with my attorney to do that, but I haven't even 19 gone back to look at all the documents that were 20 assembled. You have to show me all the documents. 21 What I have suggested is, although I 22 know you have all these documents because of 23 what's been stated in open court by Mr. Berger 24 with regard to how you were involved with the 25 retrieval of those by Mr. O'Boyle, but what I was 22 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 going to suggest was, it would probably be easier 2 if you got the link to the Dropbox, because I know 3 it's voluminous. I believe you already have a 4 link, but I can give it to you again. I suspect 5 you have more CAFI documents than I do. But the 6 Dropbox would at least show you exactly what I had 7 at that moment in time. 8 Q. I would venture to say that if 9 Mr. Chandler provided me the same documents he 10 provided you, that I already have it. But as I 11 sit here today, I don't know whether I have the 12 same documents you have or whether you have 13 something different than what I have. 14 A. I now know that I have a small 15 portion of the documents that he had because I 16 reviewed the production Mr. Chandler made in the 17 case that you filed on behalf of Mr. O'Boyle, and 18 it was substantially larger than the actual 19 Dropbox. So that's why I'm suggesting the best 20 thing to do would be to have the Dropbox link, 21 which I never opened or looked at because I didn't 22 even know how to operate a Dropbox. I had it 23 printed out, ultimately. But I would suggest that 24 if you want, we can have the Dropbox link provided 25 to you. 23 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. I appreciate that. 2 A. That would be the best way to know 3 exactly what I had at that moment in the office. 4 Q. I appreciate that? 5 MR. DE SOUZA: I'm going to go ahead 6 and mark as Exhibit Sweetapple-2 a copy of 7 Defendant Robert A. Sweetapple's response to 8 Plaintiff's First Request for Production. 9 (Whereupon Exhibit Sweetapple-2, Copy 10 of Defendant Robert A. Sweetapple's Response 11 to Plaintiff's First Request for Production, 12 was marked for Identification.) 13 MR. DE SOUZA: And for completeness, 14 I'm going to have marked as Exhibit 3 a copy 15 of Defendant Robert A. Sweetapple's Amended 16 Response to Plaintiff's First Request For 17 Production, numbers 18, 22 through 25. 18 (Whereupon Exhibit Sweetapple-3, Copy 19 of Defendant Robert A. Sweetapple's Amended 20 Response to Plaintiff's First Request for 21 Production, numbers 18, 22 through 25, was 22 marked for Identification.) 23 THE WITNESS: I wrote on yours, I'm 24 sorry. 25 BY MR. DE SOUZA: 24 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Josh has a clean one. 2 A. I'm the witness, not the lawyer. I 3 won't write numbers on the things you hand me. 4 Q. We'll forgive you because you've 5 probably been in this chair more often than not. 6 A. I've spent the last three weeks 7 taking about nine party depos, all day long. It's 8 much easier to be sitting here than sitting where 9 you're sitting. 10 Q. Let's start with Exhibit 2, 11 Mr. Sweetapple, which is your original responses 12 to plaintiff's request for production. 13 Have you ever seen this document 14 before? 15 A. I did look at it when it came in, 16 yes. 17 Q. Do you know if you reviewed it prior 18 to it being finalized? 19 A. I probably did. I recall seeing an 20 e-mail of this on my phone and reading it in the 21 middle of something I was doing. 22 Q. The original responses which is 23 Exhibit 2, there are certain categories of 24 documents here to which objections are made and 25 there's certain categories of documents for which 25 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 there's an agreement to produce. 2 I'd like to focus on the agreement to 3 produce right now. 4 A. Okay. 5 Q. So if you could turn to request 6 number 1. 7 Request number 1 asks for all 8 documents, other than court filings or discovery 9 documents, in which plaintiff's name is referenced 10 in a case caption and communications referencing 11 plaintiff's name. 12 And the response is: Sweetapple will 13 make all responsive non-privileged documents 14 within his custody or control available for 15 inspection or copying at a mutually agreeable date 16 and time. 17 MR. GOLDSTEIN: The document speaks 18 for itself. 19 MR. DE SOUZA: That's great, because 20 I haven't asked a question yet. 21 BY MR. DE SOUZA: 22 Q. As part of your efforts to gather 23 responsive documents, have you gathered documents 24 to be produced in which plaintiff's name is 25 referenced, other than in a case caption? 26 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. Yes, I've had my staff do that. I've 2 spoken to my counsel with regard to that. 3 I am, as I sit here, unaware of any 4 document that was published or disseminated other 5 than in the course of preparing drafts of 6 pleadings where Ms. DeMartini's name was written 7 and published to some third party by me. 8 Q. How would you go about finding out if 9 your office or your staff has done the search for 10 these documents and provided all these documents 11 to Mr. Goldstein? 12 A. I would speak with Cynthia Miller who 13 is my paralegal and a third year law student, 14 she's been with me for ten years, and who scans 15 everything and maintains the files. And I 16 remember having her look for this and discussing 17 with her what possibly there could be. 18 And I cannot think of any instance 19 where I wrote to any third party or communicated 20 with any third party where I used Ms. DeMartini's 21 name. 22 Q. Just to make sure we're clear. 23 When you say third party, I assume 24 you're excluding people inside your law firm. 25 A. Um-hmm. 27 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. I assume you're excluding the Town of 2 Gulf Stream which was your client at the time, 3 correct? 4 A. Correct. 5 And Mr. Richman and his attorneys 6 that I was communicating with at the request of my 7 client. Ms. O'Connor and her lawyers and 8 paralegals that were my co-counsel that I was 9 communicating with. 10 Q. Would you be excluding anyone else 11 from -- 12 A. No. I'm talking about not in the 13 gambit of confidential lawyer/client work sphere. 14 Q. Request number 2 here asks for 15 documents in which plaintiff's name is referenced 16 in which the subject matter concerns RICO, the 17 RICO lawsuit and/or the prospective filing of the 18 RICO lawsuit. 19 Again, the response is: We'll make 20 responsive documents available. 21 And again my question is: Do you 22 know whether a search has been performed for those 23 responsive documents? 24 A. I believe so. 25 Q. And do you believe that all 28 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 responsive documents to that have been turned over 2 to counsel? 3 A. To the extent that you have the 4 corporate filings from the Secretary of State for 5 CAFI, the sworn statement of Mr. Chandler, the 6 affidavit of Mr. Chandler, and the documents that 7 are in the Dropbox that are referenced in the 8 chronology itself -- and her name may have been 9 mentioned, this just occurred to me, but I don't 10 think so, in the article by the Florida Bar on the 11 new scam or in the other articles she may have 12 been mentioned. I don't even know if we looked 13 there. 14 But that's the only things I can 15 think of. 16 Q. Other than what you just testified as 17 to what you can think of, are you aware of any 18 other documents in your possession, custody or 19 control that would be responsive to this document 20 request that have yet to be turned over to your 21 counsel? 22 A. No, that's all that I think have been 23 found and I think that's all that I can think of 24 that exist in terms of the conversations I've had 25 with my paralegal and counsel. 29 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Again, with the stipulation that 2 you're excluding from that any document that you 3 consider to be privileged or work product. 4 A. Oh, yeah. If there's a transmittal 5 of a pleading back and forth, because I was asked 6 to draft the statements of facts because I was the 7 guy that had done all the investigation leading up 8 to Joel Chandler and then obviously through Joel 9 Chandler, so her name would appear in drafts of 10 pleadings, but I think that is part of the 11 exception. 12 When you say court filings, you mean 13 drafts of complaints as well, I take it. Her name 14 would appear in those. But she wasn't -- it was 15 all part of the work product. 16 Q. Let's flip ahead to request number 17 26, if you will. 18 A. Sure. 19 Q. Request 26 asks for invoices for 20 legal services provided to Gulf Stream and/or 21 Wantman for work performed concerning the 22 investigation of any claim against plaintiff. 23 Again, the answer is: We'll make 24 them available. 25 My question to you, again, is: Do 30 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 you know whether those invoices have been provided 2 to your counsel? 3 A. I believe those invoices are -- I 4 don't know if they've been provided to him. I 5 presume so. But they are also -- I think they're 6 a matter of public record. 7 MR. GOLDSTEIN: I might add, I 8 believe all those invoices were recently 9 produced by the town a week and a half ago. 10 And I'm happy to reproduce them if you'd 11 like. 12 MR. DE SOUZA: I don't know that I 13 have an entire copy of them. I have invoices 14 that look like they're in April, June, 15 October, but I don't know that I have a 16 complete set of invoices. 17 If the answer is you already have a 18 complete set, then I don't need you to 19 reproduce anything. 20 MR. GOLDSTEIN: I believe you have a 21 complete set of responsive invoices. 22 THE WITNESS: I can assure you from 23 an operational standpoint that every invoice 24 I have has been sent to the town because I 25 operate just like you do. If I don't send 31 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 them, I don't get paid. 2 BY MR. DE SOUZA: 3 Q. You'd rather get paid? 4 A. Yeah. 5 So, as I understand it, all the 6 invoices that we have have been sent to the town. 7 And I also understand, other than 8 redactions that the town's attorney makes pursuant 9 to the law, they're made public immediately. I 10 think they're posted, actually. It's a little 11 unusual type of lawyer/client relationship. 12 MR. DE SOUZA: Mr. Goldstein, will 13 you do me a favor; rather than push the 14 issue, when you review the invoices that have 15 been produced by the town and if that is 16 everything that Mr. Sweetapple generated, 17 just let me know. 18 MR. GOLDSTEIN: I will let you know. 19 BY MR. DE SOUZA: 20 Q. That's really the same for request 21 number 27, Mr. Sweetapple, which talks about 22 invoices, investigating potential RICO claims 23 against the plaintiff. I assume the invoices 24 would be no different than the ones that were in 25 26. 32 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. I was hired to handle prolific public 2 records litigation and I didn't have a separate 3 retention to hire RICO, I had no concept that 4 there was anything that I ultimately concluded was 5 criminal going on. I was hired initially -- I 6 thought I had a matter that was exclusively 7 involving public records requests when I got hired 8 in I guess April of '14. 9 Q. Do me a favor and turn to Exhibit 3. 10 A. Sure. 11 Q. Exhibit 3 are the amended responses 12 to certain of the requests. I want you to take a 13 look at the response to request number 18. 14 Request number 18 asks for production 15 of communications with any law enforcement and/or 16 prosecutorial agency concerning the allegations 17 raised in the RICO complaint. 18 As lawyers often do, your counsel has 19 about a paragraph of objections, followed by the 20 last sentence which is: Notwithstanding the same, 21 defendant Sweetapple will produce any 22 non-privileged documents responsive to this 23 request. 24 I guess my question to you is; are 25 there responsive documents to this request, 33 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 communications with law enforcement or 2 prosecutorial agencies concerning the allegations 3 raised in the RICO complaint? 4 A. From me? 5 Q. That you're aware of, that you would 6 have in your possession, custody or control, 7 whether you were copied on them, whether you were 8 the one sending them, whether you were the one 9 receiving them. 10 A. I believe that I have somewhere in 11 our offices a copy of, and I don't know if this 12 would be law enforcement, prosecutorial agency, 13 but communications with the Attorney General's 14 Office, I'd have to see the letter, I don't know 15 that it's -- I don't remember what it said, but I 16 do recall there were communications that I was -- 17 that I had a copy of involving the Attorney 18 General's Office. And I know I wrote to the 19 Attorney General's Office, but that was I think 20 well after this, with regard to -- not with regard 21 to RICO. 22 Q. To break that up. 23 You said you believe there's a letter 24 that you might have in your office, and you also 25 stated you wrote to the Attorney General's Office. 34 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Are we talking about two different -- 2 A. Yes. I think I wrote this year, and 3 that was work product, not with regard to the RICO 4 complaint. And I think I -- I'm pretty sure there 5 was a letter written, and I'm not sure if it was 6 by the client, by Mr. Richman, Ms. O'Connor. I 7 remember there was some communication with the 8 Attorney General's Office at some point. 9 Q. You believe that you still have a 10 copy of that letter somewhere? 11 A. I would think it's somewhere, 12 scanned, or in the file. 13 Q. Would you agree to provide that to 14 your counsel for production in this case? 15 A. We'll look for it. 16 MR. GOLDSTEIN: If it can be located, 17 we'll produce it. 18 MR. DE SOUZA: I can't make you 19 produce something that doesn't exist. 20 THE WITNESS: I think -- 21 MR. GOLDSTEIN: I'll follow up, 22 depending on when we finish, today or the end 23 of the day. 24 MR. DE SOUZA: Don't say that. I 25 don't want to be here that long. 35 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MR. DE SOUZA: 2 Q. You wrote to the Attorney General's 3 Office this year, correct? 4 A. That's correct. But that's work 5 product, so that's not what you're seeking here. 6 Q. I understand. 7 A. It wasn't in regard to RICO. 8 Q. I understand. 9 Can you tell me what it was in regard 10 to, the subject matter? 11 A. I don't think I could do that. It's 12 work product, it didn't involve -- it didn't name 13 Ms. DeMartini. 14 Q. Does it involve public records as the 15 subject matter or the -- 16 A. I think that's work product right 17 now... 18 Q. Let me ask you this: Do you believe 19 the letter that you wrote to the Attorney 20 General's Office is responsive to any of the 21 document requests that we have reviewed already 22 and which your counsel agreed to produce 23 documents? 24 A. I'd have to go through and look at 25 all those requests, but it doesn't relate to 36 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Ms. DeMartini or RICO, so my guess would be no, 2 without having read everything. 3 Q. Does it relate to any group of people 4 or entities that would include Ms. DeMartini? 5 A. I will say that it relates to an 6 entity that Ms. DeMartini purported to be 7 associated with in the past, and leave it at that. 8 At that point it's work product and ongoing. 9 Q. You can take it for what it's worth, 10 but I would ask that you retain a copy of that 11 letter and provide a privilege log which I think 12 I'm entitled to at least the subject matter of 13 what it is. 14 MR. GOLDSTEIN: We're working on a 15 privilege log on certain things that are 16 based upon privilege objections, anyway, and 17 I can speak to my client... 18 MR. DE SOUZA: Thank you. 19 BY MR. DE SOUZA: 20 Q. Mr. Sweetapple, I presume you've read 21 the complaint in this case. 22 A. I read it when it was served and I 23 read it last night rather quickly. 24 Q. And by "complaint," I'm referring to 25 plaintiff's first amended complaint which I 37 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 believe is dated August 2nd, 2016. 2 I'll provide a copy for you so you 3 can confirm this is the version that you read. 4 MR. DE SOUZA: We'll go ahead and 5 mark this as Exhibit 4. 6 (Whereupon Exhibit Sweetapple-4, 7 Plaintiff's First Amended Complaint, was 8 marked for Identification.) 9 BY MR. DE SOUZA: 10 Q. Do you believe this is the version of 11 the complaint which you reviewed I think you said 12 last night? 13 A. This appears to be... let me just 14 look. 15 Yeah, this appears to be the version 16 I read. And I can't say that I read, you know, I 17 studied it. I went through it pretty quickly. 18 I'm sure you understand my view of the complaint, 19 so I'm not going to editorialize it. 20 Q. In this complaint, Ms. DeMartini 21 asserts a single claim for slander per se against 22 you; is that correct? 23 A. I saw that. 24 MR. GOLDSTEIN: Speaks for itself. 25 MR. DE SOUZA: Thank you, Josh. 38 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE WITNESS: Pardon? 2 BY MR. DE SOUZA: 3 Q. I said thank you, Josh. 4 It is actually count 3 of the 5 complaint on page 20, correct? 6 A. Let me get there. 7 I did read that last night. That's 8 what I looked at to see if it was the same 9 document I read, and I remember saying I was 3 and 10 Mr. Richman was 4 and I noted that you didn't give 11 me top billing the last time you sued me, but you 12 moved me down to the very bottom this time. So I 13 did notice that. 14 Q. This may be different with some 15 defendants that don't have legal training, but 16 I'll ask you; do you understand what slander is? 17 A. I believe I do. I've litigated cases 18 to juries, both winning and losing on slander, so 19 I have some general working knowledge. 20 The first trial I had was a slander 21 case I tried before Lenore Nesbitt in 1981 in the 22 Dade County Courthouse, and I think I'm the only 23 living survivor of that litigation, actually. 24 I've watched as the parties and the judges and the 25 opposing lawyers, including Tobias Simon, all 39 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 passed away. 2 Q. I don't know whether to congratulate 3 you or... 4 A. I'm just saying, one of the first 5 cases I tried was a slander case. 6 Q. Let me ask you, since you've had 7 experience with slander; what is your 8 understanding with what the concept of slander is? 9 A. The concept of slander is that we all 10 enjoy the rights to our reputations and that 11 slander is an oral publication of words that are 12 deemed to be defamatory. And there's two 13 categories, generally; per se and per quod. Per 14 se would be the imputation of unchastity to a 15 woman; the accusation of criminal -- of a felony; 16 communicable disease or unfitness to perform your 17 profession that you hold yourself out as having 18 competence in. 19 Generally. 20 Q. Now, in this case, Ms. DeMartini has 21 asserted a claim of slander per se against you, 22 right? 23 A. She has. 24 Q. What is your understanding of what 25 Ms. DeMartini has accused you of doing? 40 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. She has accused me of making -- well, 2 it speaks for itself. We can go through it and 3 read it, but my understanding is that she 4 maintains that I have made statements of fact 5 about her; to wit, that she is a criminal and that 6 I've published those oral statements to 7 Mr. Chandler and to Mr. Hanna. 8 Q. And what is your response to that? 9 Do you agree with her allegation or do you dispute 10 it? 11 A. My response to that is that I have 12 never used her name in any oral statement, that I 13 can remember, to Mr. Hanna or to Mr. Chandler. 14 And other than my interview with Mr. Chandler -- 15 (Interruption.) 16 (Whereupon a discussion was held off 17 the record.) 18 MR. HOCHMAN: Let the record reflect 19 that Mayor Morgan has entered the room. 20 THE WITNESS: I'm sorry. I'm 21 underlining your exhibit. 22 MR. TACHER: Old habits are hard to 23 break. 24 THE WITNESS: I have not written on 25 this one. 41 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MR. DE SOUZA: 2 Q. I believe before Mayor Morgan walked 3 in, you testified that you have never used 4 Ms. DeMartini's name in any conversation with 5 either Joel Chandler or Mark Hanna; is that 6 correct? 7 A. I don't think I've ever used her name 8 with Mr. Hanna. 9 And other than with Mr. Chandler, it 10 would be my asking him questions about when I 11 debriefed him on video. 12 So you allege here that I stated to 13 third parties and/or law enforcement agencies that 14 plaintiff is a criminal. I've never done that. 15 Has committed racketeering 16 violations. I never did that. 17 Has violated the federal RICO 18 statutes. I've never done that. 19 And is guilty of extortion. I've 20 never done that to third parties. 21 And again using the term of what 22 third parties are as we previously defined it in 23 the record. 24 Q. Excluding Richman Greer, its 25 attorneys; excluding your own firm, its 42 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 attorneys... 2 A. My client, my client's other 3 counsel -- 4 Q. Jones Foster... 5 When I use the word CAFI, do you 6 understand what that entails, what entity I'm 7 referring to? 8 A. Not really, because I think that's a 9 very -- that's a whole subject unto itself, 10 whether or not it even is an entity. 11 Q. Let's define it just as the Citizens 12 Awareness Foundation, Incorporated, the entity 13 that purports to be Citizens Awareness Foundation, 14 Incorporated. 15 A. It purports to be a Florida 16 not-for-profit corporation. 17 Q. But you understand which entity I'm 18 referring to when I say CAFI, or at least which 19 purported entity I'm referring to? 20 A. I understand when you refer to CAFI 21 that you're referring to something that is called 22 Citizens Awareness Foundation, Inc., that purports 23 to be a Florida not-for-profit corporation. 24 Q. Have you ever accused CAFI, in 25 communications with third parties as we have 43 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 defined today, of committing one or more crimes, 2 including racketeering, RICO, extortion or any 3 other crime? 4 A. Where I've spoken to someone other 5 than -- 6 Q. Other than the core group that we 7 have defined that excludes third parties. 8 A. No, I don't believe I've ever done 9 that. 10 I don't think I've ever really 11 considered -- referred to CAFI as an entity that 12 would be even capable of doing anything because in 13 my mind CAFI is a sham and, so, I've never really 14 gone out and -- it's not like General Motors 15 committed fraud or General Motors is a criminal 16 enterprise. To me, CAFI is basically a sham. 17 That was my legal opinion after I 18 concluded, or in the course of, my investigation. 19 Q. I know you said you've never used 20 plaintiff's name in accusing her to any third 21 party of committing any crime, correct? 22 A. Correct. 23 MR. GOLDSTEIN: Asked and answered. 24 THE WITNESS: I don't -- I've never 25 published to anyone that I believe that 44 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Denise DeMartini was a criminal or in any 2 form involved in criminal activities. 3 I've never said CAFI was a criminal 4 or was involved in criminal activity to third 5 parties. 6 BY MR. DE SOUZA: 7 Q. What about a group of people that 8 would include the plaintiff in this case; so, for 9 example, a statement to a third party such that 10 CAFI and all of the people that worked there are 11 criminals, or have committed some type of crime? 12 MR. GOLDSTEIN: Object to form. 13 THE WITNESS: I've never made that 14 type of statement. 15 BY MR. DE SOUZA: 16 Q. What about a group of people or 17 entities that would include CAFI; have you made a 18 statement to third parties that that group has 19 committed some type of crime? 20 MR. GOLDSTEIN: Object to form. 21 THE WITNESS: Not that I'm aware of. 22 BY MR. DE SOUZA: 23 Q. You mentioned Joel Chandler a number 24 of times today. I assume you're familiar with who 25 he is, correct? 45 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. I've become familiar with him, who he 2 is. I had no idea who he was until July of 2014. 3 Q. Just for purposes of today, who is 4 Joel Chandler? 5 A. Joel Chandler is, from what I have 6 learned, an individual who was substantially 7 involved in making public records requests of 8 governments and private contractors and extracting 9 money from them by way of settlements for making 10 those public records requests and involving 11 attorneys throughout the state and making requests 12 and obtaining attorney's fees from them, thousands 13 and thousands, maybe 60,000, from what I've been 14 able to ascertain, even before he became involved 15 with Mr. O'Hare and Mr. O'Boyle. But he is 16 someone who has extensive experience in making 17 public records requests, and in the materials he 18 provided to me, actually bragged about his ability 19 to make kill shots, which he describes as the 20 types of requests and lawsuits that will be 21 guaranteed to result in attorney's fees. 22 My knowledge of Mr. Chandler, 23 basically, is with regard to his tremendous 24 expertise and involvement in extracting monies 25 from charities and governments throughout the 46 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 State of Florida by making voluminous public 2 records requests as a professional. 3 Q. What is the timeframe in which you 4 learned that about Mr. Chandler, that he's made 5 tens of thousands of requests to public agencies 6 and extracts settlements for doing this? 7 A. It would have started in July of 8 2014, when I first was contacted by him, and it's 9 ongoing, as I continue to investigate and defend 10 my client to date. 11 Q. You said Mr. Chandler contacted you 12 in July of 2014. Is that the first time that 13 you've spoken with Mr. Chandler? 14 A. Yes. 15 Q. What type of communication was that? 16 Was that over the telephone, was it via e-mail, in 17 person? 18 A. I remember that there was an e-mail, 19 I remember a press release, and I remember a phone 20 call. If you ask me what order it occurred in, at 21 this date, I can't tell you. But I recall early 22 on I saw a press release, I remember there was an 23 article, maybe. Maybe the article was later. But 24 that's the first time I even knew he had any 25 relationship with O'Boyle and O'Hare. 47 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Do you believe July 2014 was the 2 first time you communicated with Joel Chandler? 3 A. I'm sure it was. 4 Q. From July 2014 through the present, 5 have you exchanged e-mails with Mr. Chandler? 6 A. Some. Isolated. 7 I forwarded him his affidavit, asked 8 him to review it to make sure it was accurate. 9 And he sent me, you know -- we've e-mailed each 10 other, I'd be guessing, three to six times. Maybe 11 more. I don't know. 12 Q. Do you know whether those e-mails 13 have been provided to your counsel and/or produced 14 in this litigation? 15 A. I don't know. 16 Q. Do you know if any effort has been 17 made to search for those e-mails, your e-mails 18 with Mr. Chandler? 19 A. I believe so. 20 Q. I can represent to you that in terms 21 of what was produced to me yesterday, I did not 22 receive any e-mails between you and Mr. Chandler. 23 MR. GOLDSTEIN: They're still being 24 searched for. 25 MR. DE SOUZA: Still? 48 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 MR. GOLDSTEIN: Yeah. I'm hoping by 2 the end of the week. 3 MR. DE SOUZA: Not to beat that dead 4 horse; I want to confirm, I have not received 5 all of the documents that are possibly 6 responsive to -- 7 MR. GOLDSTEIN: I believe you've 8 received the majority of them. I think 9 there's e-mails -- to the extent they are not 10 considered privileged or being responsive, 11 there's still being worked on. 12 THE WITNESS: I can tell you that I 13 would not -- I did not mention Ms. DeMartini 14 in any e-mail to Mr. Chandler. 15 MR. DE SOUZA: I think the 16 interrogatory responses, one of them says 17 e-mails with Chandler will be produced. 18 MR. GOLDSTEIN: Yeah, I do believe it 19 does say that. 20 BY MR. DE SOUZA: 21 Q. Other than e-mailing Mr. Chandler, 22 have you spoken to him, either in person or on the 23 telephone? 24 A. Sure. I've called him up and asked 25 him questions about things in the case, I've asked 49 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 if he's available to be a witness. I called him 2 up after Marty said he was a pedophile at a 3 deposition, made him aware that that had occurred. 4 That was the last communication I had 5 with him. 6 Q. Have you ever spoken to Mr. Chandler 7 for purposes of discussing Ms. DeMartini? 8 A. No, other than what I obtained from 9 him in the interview and the affidavit. 10 Q. You interviewed him at some point. 11 Was that in July 2014? 12 A. Yes. 13 Q. And is this where you took a sworn 14 statement from him, which there's over a hundred 15 page transcript associated with? 16 A. That's the videotape. That was in 17 July, yes, 2014. 18 Q. There was a court reporter there 19 during that meeting? 20 A. Yes. 21 Q. In addition to that sworn statement 22 you obtained from him, there was also an affidavit 23 I think Mr. Chandler submitted; is that correct? 24 A. Yes. 25 Q. And do you recall when that affidavit 50 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 was submitted or prepared? 2 A. I would say it was within a couple 3 months of the time I took his statement. I needed 4 to file something in a court proceeding. 5 Obviously I couldn't file a transcript of an 6 interview, even though it was sworn to -- I guess 7 I could have probably treated it as a notarial 8 from the court reporter, but I decided that 9 probably it would be best to have a standard form 10 affidavit. And I would say it was within a couple 11 of months. 12 Q. A couple months after -- 13 A. I'd have to look at it and make sure 14 when it's dated. 15 Q. Who drafted that affidavit? Was that 16 your office, was that Mr. Chandler? 17 A. I believe I prepared it after 18 speaking to him. I e-mailed it to him. He 19 corrected it, revised it, sent it back. That's my 20 recollection of what happened. And I e-mailed and 21 said, make sure everything is accurate. But I 22 used his sworn statement as the template for the 23 affidavit. 24 Q. And that affidavit was used in 25 connection with some motion or pleadings you were 51 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 filing -- 2 A. Filed somewhere. The court records 3 will show where it was filed. 4 Q. I assume that you relied on the 5 affidavit in some way with something you were 6 filing; is that fair? 7 A. Yeah. 8 Q. In relying on that affidavit, did you 9 then consider Chandler to be a credible witness as 10 to the subjects that were in that affidavit? 11 A. Yeah. 12 By the time I filed the affidavit, I 13 did a number of things. 14 I always want to make sure my 15 witnesses are credible because there's nothing 16 more embarrassing than being in trial and finding 17 out your client didn't tell you the truth. 18 I very quickly, after taking 19 Mr. Chandler's statement, went back and compared 20 the documents that were in -- that I had printed 21 out into a notebook, and read e-mail for e-mail 22 what was in the chronology, and compared it to 23 what he had told me. And I saw that -- I didn't 24 see anything that he had represented that wasn't 25 borne out by the actual documents themselves. 52 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 And then I decided that I should take 2 Mr. O'Boyle's deposition and see what he said. 3 And you were there. 4 And Mr. O'Boyle -- and you had 5 represented CAFI so I presume you had the records. 6 And you had represented Mr. O'Boyle individually. 7 And I asked Mr. O'Boyle repeatedly under oath 8 whether or not he had anything to do with CAFI. 9 And time and time again, no matter what topic I 10 went into regarding his involvement, he 11 categorically denied he had anything to do with 12 CAFI, which was contrary to every piece of 13 evidence that I had; not just Mr. Chandler's sworn 14 statement, but e-mails and writings that I had 15 provided by Mr. Chandler, that item by item 16 contradicted Mr. O'Boyle's sworn statements. 17 So I pretty much in my mind had 18 flushed out who was telling me the truth and who 19 wasn't, very early on in my analysis of this 20 investigation. 21 Q. At that point in time, and we're 22 talking July 2014 to let's say October 2014, you 23 believe that Chandler was telling the truth? 24 A. As to the things that were in his 25 sworn statement, I had been able to corroborate 53 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 them with his own records. And, also, I had begun 2 to corroborate them with my own investigation 3 regarding Mr. O'Boyle and Mr. O'Hare and Jonathan 4 O'Boyle. 5 Q. How many times have you met with Joel 6 Chandler actually in person? 7 A. I can safely say that I know I've met 8 with him twice. Five hours I spent with him, six 9 hours I spent with him, whatever that was. And 10 then when you deposed him in the case that was 11 brought against me and then dismissed. I was 12 there for that many-hour deposition and I did talk 13 to him then. 14 I don't recall ever personally 15 meeting with him beyond that. 16 Q. And you've spoken to him on the phone 17 as well -- 18 A. Yeah. 19 Q. In any of your communications with 20 Joel Chandler, did the subject of racketeering 21 come up? 22 A. I believe that I made Mr. Chandler 23 aware at some point that the town was 24 investigating the filing of the civil RICO case 25 against Mr. O'Hare and Mr. O'Boyle. 54 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Do you believe that would have been 2 in July 2014, the first time that you -- 3 A. No. 4 Q. -- met with Mr. Chandler? 5 A. No. 6 Q. Sometime thereafter? 7 A. Yeah. It would have been well 8 thereafter. 9 Q. When I say did RICO come up in any of 10 your conversations, I assume the answer is yes. 11 You said you discussed with him the town was 12 investigating the civil RICO action. 13 A. And I believe I, and I don't remember 14 exactly, I don't want to testify to something -- 15 I'm trying to remember. 16 I remember there was some desire that 17 he be a witness. I remember Mr. Richman wanted to 18 be assured that Mr. Chandler was still willing to 19 testify. 20 There was great concern because 21 Mr. Chandler made statements to me in a 22 conversation regarding your involvement with 23 Mr. O'Boyle at a bankruptcy proceeding where 24 Mr. O'Boyle and he were talking about substantial 25 amounts of money being paid to Mr. Chandler and 55 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 him not testifying. 2 So I think the conversation would 3 have been after your involvement with Mr. O'Boyle 4 and Mr. Chandler, where Mr. O'Boyle was objecting 5 to Mr. Chandler's bankruptcy, and there were 6 discussions regarding money to change 7 Mr. Chandler's testimony. 8 Q. You believe any conversation about 9 RICO or racketeering with Chandler would have 10 occurred after Mr. Chandler had a deposition in 11 his bankruptcy case? 12 A. I believe that one conversation I had 13 with him regarding his becoming a witness was 14 based on concerns that were ongoing, from our side 15 of the table, let's say, our team, that 16 Mr. Chandler was, while let's say a whistle-blower 17 or an informant, certainly we were concerned about 18 whether or not he was going to be willing to 19 testify or be telling the facts as we knew them, 20 in light of the dealings we were being informed of 21 that he was engaged in with Mr. O'Boyle and you 22 and his bankruptcy. 23 And I'm not sure that was the first 24 time that I told him that the lawyers were 25 investigating a potential civil RICO suit, but all 56 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 my conversations with him were with regard to, you 2 know, are you willing to be a witness. 3 Keep in mind that Mr. Chandler made 4 it clear to me that Mr. O'Boyle had threatened him 5 repeatedly. And part of his motivation, I learned 6 after reading the e-mails, was a result of 7 Mr. O'Boyle's threats, to great unpleasantness 8 upon him, I think is what he said and what is 9 borne out by the e-mails. 10 Q. When you state that you told 11 Mr. Chandler that the town was investigating the 12 civil RICO action, I believe you said against 13 Mr. O'Boyle and Mr. O'Hare; is that right? 14 A. That's the only two people we ever -- 15 I ever mentioned. 16 Q. Did you mention Mr. O'Boyle and 17 Mr. O'Hare and their cohorts, or something 18 suggesting that the civil RICO action would be 19 against more than just Mr. O'Boyle and Mr. O'Hare? 20 MR. GOLDSTEIN: Object to form. 21 MR. HOCHMAN: Form. 22 THE WITNESS: No. 23 BY MR. DE SOUZA: 24 Q. Did you tell Mr. Chandler that you 25 believed that Mr. O'Boyle did commit acts of 57 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 racketeering? 2 A. I don't believe I said what my belief 3 was. I think he could imply from my statement 4 that we were investigating, that I believe there 5 was a bona fide factual basis for that 6 investigation. 7 Q. And with respect to Mr. O'Hare, did 8 you make a statement to Mr. Chandler that 9 Mr. O'Hare did in fact commit an act of 10 racketeering? 11 A. No. 12 MR. GOLDSTEIN: Form. 13 BY MR. DE SOUZA: 14 Q. As far as you recall, the only 15 statement you made was the town was investigating 16 a potential RICO or racketeering action, correct? 17 A. Right. 18 Q. Did you tell Mr. Chandler that a 19 crime had been committed by any person? 20 A. No. 21 Q. Did you tell Mr. Chandler that any 22 person or group of persons had committed an act of 23 extortion? 24 MR. GOLDSTEIN: Form. 25 THE WITNESS: No, but I think I did 58 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 mention to him at some point we were 2 investigating abuse of process, extortion... 3 I did mention to him theories we were 4 investigating. 5 BY MR. DE SOUZA: 6 Q. When was the last time you 7 communicated with Mr. Chandler? 8 MR. GOLDSTEIN: Asked and answered. 9 THE WITNESS: I think it was in 10 connection with the deposition that 11 Mr. O'Boyle took of me which was about six 12 months ago, wherein he blurted out, I think 13 Mr. Chandler is a pedophile. And then 14 retracted it. And I called him and said, you 15 should be aware that this is what's 16 occurring. 17 BY MR. DE SOUZA: 18 Q. This is a deposition that was in the 19 case that I was formerly counsel in? 20 A. Right. 21 It's in the transcript. I think 22 Mr. Hochman even had it marked. 23 Q. Do you know who Mark Hanna is? 24 A. I do. 25 Q. And who is Mark Hanna? 59 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. Mark Hanna was a lawyer who practiced 2 in Florida. I think he's relocated to Ohio, from 3 what I understand, but he represented Mr. O'Hare 4 in certain public records requests and his wife 5 represented Mr. O'Boyle and Mr. O'Boyle's 6 entities. So he was involved with Mr. O'Boyle, 7 representing Mr. O'Hare, and his wife was the 8 lawyer who actually formed the CAFI enterprise, 9 the alleged entity. 10 Q. Did Mr. Hanna represent Mr. O'Hare in 11 any of the public records litigation in which you 12 were counsel for the town? 13 A. Yes. 14 Q. So I assume it's safe to assume that 15 you have spoken to Mr. Hanna before? 16 A. I spoke to Mr. Hanna on a number of 17 occasions. 18 Q. And did the subject of racketeering 19 come up in any of your conversations with 20 Mr. Hanna? 21 A. Well, I'm not going to disclose what 22 occurred at a confidential settlement conference 23 where we all signed an agreement that it would be 24 treated as mediation, but other than that, I do 25 not -- I don't recall if I disclosed to him that 60 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 we were investigating a civil RICO claim separate 2 and apart from this settlement conference. 3 Q. Let's set the parameters of what you 4 are testifying to and not testifying to. 5 You just talked about a settlement 6 conference or meeting. Do you recall when the 7 date of that was? 8 If I said September 3rd, 2014, does 9 that sound right? 10 A. That sounds correct. 11 Q. Before we get there. You're 12 excluding that from your answer at this point. 13 A. Yeah, because I don't want to be sued 14 for -- while I believe Mr. -- strike that. 15 Because there's a signed agreement, 16 I'm not going to testify as to what was said at 17 the conference or settlement conference. 18 Q. Other than the September 3rd, 2014 19 conference, do you believe the subject of 20 racketeering has come up in any of your 21 conversations with Mr. Hanna? 22 MR. GOLDSTEIN: Asked and answered. 23 THE WITNESS: I'm not sure if I 24 disclosed to him -- we had some other 25 settlement conferences where I was trying to 61 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 get Mr. O'Hare to settle, and my goal was to 2 get him to testify against Mr. O'Boyle. And 3 I don't remember if I, in any of those 4 conversations, disclosed to him that we were 5 investigating civil RICO or investigating 6 alleged -- any alleged claims that we had. 7 BY MR. DE SOUZA: 8 Q. Again, excluding September 3rd, 2014, 9 do you recall whether the subject of extortion 10 came up in any of your conversations with 11 Mr. Hanna? 12 MR. GOLDSTEIN: Asked and answered. 13 THE WITNESS: I know that we were 14 researching, investigating, you know, claims 15 for abuse of process, extortion, and 16 Mr. Hanna and I were debating legal theories 17 in different settings and whether or not a 18 claim existed or not and what the elements 19 were. 20 And I -- it's possible -- I can't 21 even sit here -- I remember physically where 22 I was when I had a couple conversations with 23 him, but exactly what was discussed there; 24 some were involved and fast-moving and we 25 were debating things and I was suggesting to 62 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 him that Mr. O'Hare should settle and he 2 shouldn't be involved with these people, he 3 should extricate himself. 4 I may have indicated to him what we 5 were researching or what our theories were, 6 but I don't remember specifically. 7 BY MR. DE SOUZA: 8 Q. Other than September 3rd, 2014, have 9 you ever told Mr. Hanna that any person or group 10 of persons committed a crime? 11 MR. GOLDSTEIN: Form. 12 THE WITNESS: I've never said that 13 someone is a criminal or a racketeer. I've 14 not done that. I'm talking as a lawyer in 15 terms of legal theories and claims between 16 clients. 17 BY MR. DE SOUZA: 18 Q. To short-change it, whether it's 19 Mr. Hanna, Mr. Chandler or any third party, have 20 you ever said someone is a criminal? 21 MR. GOLDSTEIN: Object to form. 22 BY MR. DE SOUZA: 23 Q. I'll say in the last two years, since 24 April of 2014. 25 MR. GOLDSTEIN: Form. 63 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 THE WITNESS: You mean just as to the 2 people involved in this case, or anybody? 3 BY MR. DE SOUZA: 4 Q. Let's say the people involved in the 5 RICO -- any of the RICO defendants; have you said 6 to any third party, any one or more of those RICO 7 defendants is a criminal? 8 A. No. 9 Q. Have you said, any one or more of 10 those RICO defendants committed an act of 11 racketeering? 12 MR. GOLDSTEIN: Form. 13 THE WITNESS: No, not -- make a 14 statement, he's committed an act of 15 racketeering or he is a criminal? No. 16 BY MR. DE SOUZA: 17 Q. He's committed an act of 18 racketeering. No? 19 A. No. But obviously I've said, you 20 know, we believe -- I don't want to get into the 21 settlement conference. There have been statements 22 made about legal theories. 23 Q. We can exclude that September 2014 24 conference for now. I'm just trying to get in 25 general, over the last couple of years, exclude 64 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 that conference; have you said any one or more of 2 the RICO defendants committed an act of 3 racketeering? 4 MR. GOLDSTEIN: Form. 5 THE WITNESS: I don't believe so. 6 BY MR. DE SOUZA: 7 Q. Have you said, any one or more of the 8 RICO defendants committed a violation of RICO? 9 A. Not in that form, no. 10 MR. GOLDSTEIN: Form. 11 BY MR. DE SOUZA: 12 Q. In some other form? 13 A. I mean, I've said that we're 14 investigating, we believe we have bona fide 15 claims. The town may file. The town is working 16 on a complaint. The town is -- you know, 17 basically just your typical legal statements that 18 you would make to an opposing counsel in 19 disclosing where you're going and what you're 20 doing and where you think the case is going to go. 21 And that's it. I haven't run around saying 22 Ms. DeMartini is a racketeer or she's a criminal 23 or, you know, to anyone, which is why I found your 24 complaint outrageous. 25 But I understand that Mr. O'Boyle is 65 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 an important client of yours and when I questioned 2 the court last month, I asked him to confirm that 3 the case he filed against me was dismissed, he 4 said yes, under oath, he said, yes, but it's been 5 refiled. So he actually views the DeMartini case 6 as a refiling of his case. 7 So I understand the position you're 8 in, but I can assure you that count 3 is an utter 9 sham. 10 Q. Do you believe that Mr. O'Boyle has 11 some involvement in this case? 12 A. I believe, Dan, that Mr. O'Boyle, 13 who's referred to as Big Daddy by the people that 14 he works with that are in the e-mails pays for 15 everything. I believe he is the funding source 16 for all of the other individuals that are involved 17 in his activities. 18 And I know that you've represented 19 him, you've represented CAFI, you've 20 represented -- you're representing Ms. DeMartini. 21 So my suspicion is that, in light of the fact that 22 he said that he has refiled the case, that you 23 have some ongoing relationship with Mr. O'Boyle. 24 Q. You believe I have an ongoing 25 relationship with him or that my client has an 66 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 ongoing relationship with him, or both? 2 A. Well, based on my opinions and 3 conclusions I've reached regarding your client -- 4 your clients', plural, integrity, I have opinions 5 as to whether or not your client and 6 Ms. DeMartini, who have a long-standing, very 7 close relationship, is ongoing or not ongoing. 8 So, that's just my opinion, but I 9 would be very suspicious of any notion that they 10 do not have an ongoing relationship. And the fact 11 that you are representing both of them and have 12 been representing Mr. O'Boyle and CAFI and have 13 been involved in many of these players as a lawyer 14 would be one of the flags that make me believe 15 that he still has an ongoing relationship with 16 Ms. DeMartini. 17 Q. I believe you said you formed 18 opinions as to my clients' integrity. 19 I really don't care about Mr. O'Boyle 20 at this point. I'm asking if you have formed 21 opinions as to Denise DeMartini's integrity. 22 A. Certainly, based on the e-mails I've 23 read and the sworn statement Mr. Chandler 24 provided, I think that anyone who believes it's 25 appropriate to run around the state manufacturing 67 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 kill shot public records requests and serving them 2 on Lutheran children's services, autistic 3 children's services, schools, governments, in mass 4 form in order to create noncompliance and then to 5 attempt to obtain monies under the guise that they 6 were earned attorney's fees that were four and 7 five, ten times what was actually incurred; to me, 8 that indicates a complete lack of integrity on the 9 part of anyone who engages in that activity. And 10 it's the worst type of corruption because it's 11 insidious and rocks the core of society. 12 In 36 years of practicing law, I've 13 heard a lot of people criticize lawyers. What 14 I've learned is, if it weren't for lawyers and 15 judges, we'd have anarchy. And the worst type of 16 corruption is corruption that the law is involved 17 in. If the legal system doesn't work, we're all 18 going to hell in a handbasket. 19 When you, under the guise of using 20 the law, just rip off governments and charities 21 and create sham companies and then lie about your 22 attorney's fees and create a windfall scheme and 23 you're confronted with it and you insist you're 24 going to keep doing it and then you get an opinion 25 from another lawyer that it's okay to do that, let 68 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 me tell you something, it's a good way to destroy 2 society. 3 I've said it 20 times. You give me 4 ten computers and ten lawyers and with the kind of 5 outrageous conduct that I've seen in this case, 6 you can destroy this state, you can control, you 7 can shut down any government entity you want with 8 robocalling, public records requests; and it's the 9 lack of integrity and the use of the law as a 10 scheme, fraudulent scheme, that is the worst type 11 of corruption. It's corruption committed by 12 people using the legal system. That's more 13 dangerous than somebody using a gun, because 14 that's not where it's supposed to happen. 15 Q. You stated a lot, but if I could 16 summarize what you just said. 17 I think it applies generally to 18 people who do this type of conduct. 19 A. No. What I'm saying is that 20 Ms. DeMartini and Mr. O'Boyle and Mr. O'Hare, 21 based on the documents that I have reviewed and 22 the investigation I have conducted over the 23 last -- over two years now, I've concluded that 24 there's a complete lack of integrity in those 25 individuals. 69 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 And what I did is I went on to give a 2 speech, which I shouldn't have done, about why I 3 think it's the worst type of lack of integrity, 4 because it corrupts the legal system. It's an 5 abuse of the legal system. 6 And this is happening in California 7 and the laws are changing very quickly. 8 You have cases where there aren't 9 real plaintiffs, they don't exist, there aren't 10 real accidents, there aren't real not-for-profit 11 companies that are being named as plaintiffs; 12 they're all shams. 13 And the law has always protected 14 lawyers in litigation with an absolute privilege, 15 but the law is changing because, as the Florida 16 Legislature has recognized and as the California 17 courts and other courts are recognizing, schemes 18 to defraud are being perpetrated by lawyers now, 19 not just by con men. 20 There are so many lawyers that 21 lawyers are now involved in schemes and fraud. 22 And our courts are actually being used as 23 mechanisms for fraud. 24 Q. Your conclusion as to lack of 25 integrity, does that apply to Joel Chandler as 70 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 well? 2 A. I think that Mr. Chandler has been 3 honest with me with regard to most things. He has 4 not been totally honest with regard to Mr. O'Hare. 5 He has told me things about Mr. O'Hare and then 6 attempted to cover Mr. O'Hare. 7 As far as his conduct, my opinion as 8 to Mr. Chandler's conduct is that it totally lacks 9 integrity. Mr. Chandler is doing the same types 10 of things; using, abusing the public records laws 11 before, and I don't think -- I think what it's 12 going to do is it's going to end up destroying the 13 right to, or circumventing or limiting the most 14 liberal public records rights we have in this 15 state, and they're going to end up being 16 contracted. And that was something that Joel said 17 he was concerned about. But I think that Joel's 18 conduct is also responsible for why that's going 19 to happen. 20 And I suspect, I'm speculating, that 21 as a result of his abuses, Mr. O'Boyle's abuses -- 22 MR. GOLDSTEIN: Don't speculate. 23 THE WITNESS: Ms. DeMartini's abuses. 24 I'm just speculating that that's going to end 25 up unfortunately impacting the law. 71 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 The Legislature has been, as you 2 know, taking steps in that regard. 3 BY MR. DE SOUZA: 4 Q. You believe that Joel Chandler's 5 conduct in how he serves public records requests 6 and files these public records lawsuits 7 demonstrates a fundamental lack of integrity by 8 Mr. Chandler, right? 9 MR. GOLDSTEIN: Object to form. 10 THE WITNESS: My personal opinion is 11 that Mr. O'Boyle used Mr. Chandler as his 12 agent to go around videotaping, 13 surreptitiously, nonstop, dozens and dozens 14 of targets to obtain litigation for 15 Mr. O'Boyle's son, and was paid by 16 Mr. O'Boyle and has Mr. O'Boyle's credit card 17 and said that it was for CAFI, ultimately, 18 but CAFI was a sham. 19 So I certainly don't think that 20 Mr. Chandler, you know, is lilly white at 21 all. 22 Keep in mind, I have some experience 23 having worked in criminal law and my first 24 job was interning in the Public Defender's 25 Office in Dade County during the Mariel 72 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Boatlift, so I have yet to see an informant 2 who's describing conduct that I ultimately 3 conclude is criminal who, you know, is going 4 to church every day and doing everything by 5 the book. 6 So I certainly would not sit here and 7 say that I think that Mr. Chandler was not a 8 participant in these activities. He did, 9 however, see fit to extricate himself and, 10 during our early communications, told me that 11 his lawyer said he needed to go very public 12 and he needed to extricate himself from this 13 quickly. And that's one reason he -- the 14 press came to me and went to others. 15 So in that regard I guess he either 16 demonstrated integrity or decided that, based 17 on what he was saying, he better get off the 18 bus pretty quick. 19 BY MR. DE SOUZA: 20 Q. In July 2014, did you meet with 21 Mr. Hanna and Joanne O'Connor at the Jones Foster 22 office in West Palm Beach? 23 A. We had a conference at the Jones 24 Foster office... you're asking me the month? I 25 think one of the earlier conferences we had was 73 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 July or August, perhaps. 2 Q. If I showed you the invoices from 3 your firm for the month of July -- 4 A. I'll take your word for it. Give me 5 the date and I can say that's the date. 6 Q. I don't want to put words in your 7 mouth, so why don't I show you the invoice from 8 your firm and I'll point to your particular entry 9 and we can look at that together. 10 (Whereupon Exhibit Sweetapple-5, 11 Invoice from Sweetapple, Broeker, Varkas, 12 P.L., was marked for Identification.) 13 THE WITNESS: Which date? 14 BY MR. DE SOUZA: 15 Q. Before we get there. 16 Exhibit 5 appears to be an invoice 17 from your law firm, Sweetapple, Broeker, Varkas, 18 P.L.; is that correct? 19 A. Yes. 20 Q. It's stamped received July 28, 2014, 21 Town of Gulf Stream at the top. 22 A. Right. 23 Q. Looking to the second page, the 24 bottom of the page, July 24th, 2014, there's an 25 entry here: Travel and attend meeting with 74 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 opposing counsel and Joanne. Then goes on and 2 says: Conferences with Scott. And there's a 3 two-hour timeframe marked here. 4 A. Right. 5 Q. Do you believe that this is when you 6 traveled to the Jones Foster office and met with 7 Joanne O'Connor and Mark Hanna? 8 A. Yes. Within that -- sometimes you 9 put the wrong date in your -- I think it would be 10 within a day or two of that. 11 Q. Okay. What was the purpose of that 12 meeting? 13 A. I remember the purpose of that 14 meeting was pretty much the same as most of my 15 meetings with Mr. Hanna, which was to discuss 16 whether or not I could settle Mr. O'Hare's public 17 records request cases. 18 And at that point I had already met 19 with Mr. Chandler and I wanted to know whether or 20 not Mr. O'Hare was inextricably joined at the hip 21 with Mr. O'Boyle, or whether or not he was willing 22 to discuss settlement separate and apart from 23 Mr. O'Boyle. 24 Q. Do you recall whether that was the 25 stated purpose of the meeting or whether it was 75 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 actually a scheduling conference or some other 2 meeting? 3 A. I think we had had -- I think it was 4 some type of a -- I don't want to speculate. 5 There was a scheduling conference in 6 court, I remember, and I don't know if we went 7 back -- it wasn't like the stated purpose where I 8 had raised the subject with him either at the 9 courthouse and we went there or previously at the 10 courthouse before I took Chandler's statement. I 11 have to look here and see if I have any prior 12 meetings with... 13 I seem to remember the first time I 14 discussed settlement with Mr. Hanna, I believe I 15 was at the courthouse and we had come out of a, 16 maybe a scheduling conference. I thought that was 17 before I took Mr. Chandler's statement, but I'm 18 not sure. 19 This was not -- we didn't say, we're 20 having a settlement conference. But every time I 21 was with him, I was trying to find out, is 22 Mr. O'Hare willing to settle. Is this really 23 something he's doing for his roof, as I was told. 24 Or is he involved in something greater. 25 So I was feeling him out on that 76 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 issue. 2 MR. GOLDSTEIN: Before you ask the 3 next question, when is a good chance I could 4 use a restroom? 5 MR. DE SOUZA: How about right now? 6 MR. GOLDSTEIN: Okay. I didn't want 7 to interrupt your flow of questions. 8 MR. DE SOUZA: The next question was 9 going to be the doozy. 10 (Whereupon a recess was taken.) 11 BY MR. DE SOUZA: 12 Q. Jumping ahead to the September 3rd, 13 2014 meeting that you had with -- I believe Mark 14 Hanna was there, Chris O'Hare was there, Lou 15 Roeder and Joanne O'Connor, right? 16 A. And Scott Morgan. 17 Q. And Scott Morgan. 18 At that meeting there was a document 19 signed, something agreeing to treat it as 20 confidential. Is that correct? 21 A. And we originally were going to have 22 a mediation and we didn't. We did it so quickly 23 that we just prepared a handwritten agreement. 24 Q. Okay. Without discussing that, jump 25 back to the July meeting with Mr. Hanna and Joanne 77 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 O'Connor. 2 I assume there was no written 3 agreement prepared at that meeting stating that 4 everything we discuss is going to be confidential 5 or subject to mediation rules. 6 A. No, but I did say to Mr. Hanna when I 7 talked to him about settlement, let's talk about 8 settlement, this is something we ought to be able 9 to resolve. And it was understood that it 10 wouldn't be admissible in that proceeding, it was 11 a confidential dialogue. 12 Q. Did Mr. Hanna indicate that he 13 understood it was confidential? 14 A. I think lawyers understand when you 15 say, we're talking settlement, that it's 16 settlement communication. Just means it won't be 17 entered into -- 18 Q. I'm just trying to get at; was there 19 any actual acknowledgment by Mr. Hanna that he 20 would treat that conversation as confidential, as 21 far as you recall? 22 A. I don't recall. But I do recall I 23 was saying, can't we settle and won't he 24 cooperate. 25 Q. Do you know if during that meeting, 78 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the July 2014 meeting, that you made any 2 statements that the Florida Bar was investigating 3 any conduct? 4 A. No, I didn't say that. Florida Bar 5 was investigating any -- 6 Q. That the Florida Bar was 7 investigating some form of conduct. 8 MR. GOLDSTEIN: You're talking about 9 the September 3rd meeting? 10 BY MR. DE SOUZA: 11 Q. No. This is July. This is the 12 meeting at Jones Foster office. 13 A. In July, I had filed a motion to 14 disqualify the O'Boyle law firm, and I know at 15 some point I discussed with Mr. Hanna the fact 16 that that was pending. And he had filed a motion 17 to disqualify me at some point, but it was well 18 after this. 19 But I do recall, in conversations 20 with Mr. Hanna, talking about the issue of 21 unlicensed practice of law, specifically that I 22 remember the O'Boyle law firm had filed a number 23 of public records cases before they were 24 incorporated in the State of Florida. 25 The O'Boyle law firm had represented 79 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 that the parent company, so to speak, was in 2 Pennsylvania, and yet my investigation had 3 revealed that Jonathan had told the Pennsylvania 4 Bar that he was inactive and was residing in Gulf 5 Stream. And Chandler's statement was obviously 6 that Jonathan O'Boyle was actively running the law 7 firm and practicing law in Florida even though he 8 wasn't a lawyer. 9 I wouldn't have discussed a bar 10 complaint, but I do know that we were discussing 11 bar issues in terms of whether or not the cases 12 that had been filed before it was even formed and 13 whether or not it was bona fide, and it was my 14 position in the motion that the firm was not bona 15 fide. 16 Q. Do you believe those bar issues were 17 discussed with Mr. Hanna at the July 24th, 2014 18 meeting? 19 A. I really don't remember. I just do 20 remember -- I remember talking about -- the motion 21 was filed I think early on in my -- one of the 22 first things I did was discover that the firm 23 already was filing lawsuits before they were even 24 recognized as being incorporated. So it was early 25 on that I filed that motion. 80 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 It would have been, I think, in my 2 earlier conversations with Mr. Hanna, I believe is 3 when we talked about -- and I remember him saying 4 that only the bar -- I remember his position was 5 only the bar could deal with unauthorized practice 6 of law, that the court didn't have authority, and 7 I remember debating with him that the issue 8 whether or not you would be entitled to fees if 9 you filed a -- even if you're the lawyer, and 10 Mr. Whitmer (ph.) had signed the complaints, but 11 he said he was doing it on behalf of the law firm 12 which hadn't been incorporated yet. They sent the 13 papers in, but there were three or four cases that 14 were filed a week or two before they were even 15 allegedly a corporation, much less attacking their 16 standing. 17 And his position was that only the 18 bar could deal with that issue. And I said, no, 19 the court would be looking at whether or not, for 20 attorney's fees entitlement, at the very least, 21 that complaint was filed by that entity, that 22 entity is the one looking for fees in the 23 complaint. 24 I remember we talked about the bar 25 vis-a-vis the unlicensed practice of law issue. 81 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 And that was I think in the earlier stage of our 2 communications. 3 Q. Would July of 2014 been the earlier 4 stage of your communications with -- 5 A. If that's the first time it says 6 opposing counsel on the bill -- any time I spoke 7 with him for any length of time, I would have used 8 his name or referred to opposing counsel. 9 Q. During this July 24, 2014 meeting 10 with Mr. Hanna, was there any discussion about a 11 state attorney potentially investigating any 12 crimes? 13 A. No. But at some point, when I was 14 talking about O'Boyle, I did mention the state 15 attorney to him, but I never said the state 16 attorney is investigating somebody. 17 Q. How did the state attorney come up in 18 the -- would this have been in July 2014? 19 A. I don't know the date. 20 At some point when we were talking 21 about Mr. O'Boyle's involvement and activities, I 22 referred to the state attorney. 23 I don't know if you're familiar with 24 the whole -- I'm sure you are -- the whole 25 involvement Mr. O'Boyle had with the state 82 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 attorney. And I would just drop hints with him, 2 like one conversation I had was like with the 3 dolphin fin, I wouldn't lay all my cards on the 4 table, but I let him know that I knew about the 5 state attorney, that I was now realizing I'm not 6 dealing with somebody that's just filing a lot of 7 public records requests because they're trying to 8 get a roof. 9 Q. Did you let Mr. Hanna know that you 10 were in contact with the state attorney? How did 11 the state attorney come up -- 12 A. I think I mentioned that I had 13 reviewed and was familiar with what was going on 14 with the state attorney or what had gone on with 15 the state attorney. 16 Q. After that meeting in July, did you 17 then meet with Mr. Hanna in August of 2014 at your 18 office in, I believe it's Boca Raton? 19 A. He testified to that in the 20 deposition I took of him. 21 I wracked my brain and I vaguely 22 remember that -- I seem to think he came into my 23 office briefly, but I'm not sure if that was the 24 same time that was -- as the settlement 25 conference. 83 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 He remembers that we had a conference 2 at my office, and I don't have any specific 3 recollection. I've talked to him about that. 4 Because we have talked about our conversations 5 where we've laughed about how he thought one thing 6 and another, like he thought I was trying to 7 intimidate her, that I had an investigator on his 8 wife and daughter and he was all concerned, and 9 I'm like, where did you get that? And he told me. 10 Q. If a meeting occurred between you and 11 him in August of 2014, you wouldn't recall the 12 specifics of what was said or who said it at this 13 point? 14 A. No, but I generally recall the 15 conversations that I had. 16 I remember physically the courthouse, 17 I remember physically Joanne's office, I remember 18 my office where a conference... I don't remember 19 him separately being in my office for any reason. 20 I don't know if -- we could look at my bills. But 21 he does. 22 Q. According to Mr. Hanna, from what I 23 have gathered, a meeting occurred at your office 24 on August 12th, 2014 between you and him. 25 A. Do we have an August invoice? 84 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. I have looked and I have not seen any 2 produced at this point. 3 A. Okay. If I had a meeting with him 4 about this case, I would more than likely bill it. 5 So I guess we need to look at the August bill. 6 Q. The bills that have been produced to 7 me thus far by Gulf Stream seem to skip from July 8 to October. I don't see September or August in 9 the bills. I might be missing something. 10 A. Okay. Even if I saw that on a bill, 11 that wouldn't help me any more because I only 12 remember -- I remember him in my office just 13 walking around, not just in the conference room 14 talking; in the foyer, talking outside, but I 15 don't remember a separate time where he came to my 16 office for any reason. 17 Q. If that meeting occurred in August 18 2014 at your office, you wouldn't recall, as you 19 sit here today, what the purpose of that meeting 20 would have been? 21 A. I can tell you that from the first 22 time I met Mr. Hanna, I made it clear to him that 23 my purpose was to find out if I could settle with 24 Mr. O'Hare separately, or whether or not he was 25 joined at the hip with Mr. O'Boyle, in light of 85 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the fact that they were joint plaintiffs, in light 2 of the fact that Mr. Jonathan O'Boyle was 3 representing Mr. O'Hare pro hac vice in some other 4 cases, federal type cases I wasn't involved in, 5 and I wanted to know, look, is Mr. O'Hare 6 individually doing this or is he doing it in 7 concert with Mr. O'Boyle. And I quickly got my 8 answer to that after the mediation, based on what 9 occurred, or the settlement conference. 10 Q. We identified earlier there was a 11 meeting in September 2014, September 3rd, 2014, 12 between yourself, Mark Hanna, Mayor Morgan, Chris 13 O'Hare, Lou Roeder and I believe Joanne O'Connor, 14 right? 15 A. Right. 16 Q. And at that meeting, a document was 17 signed upon which there was an agreement reached 18 to do what, as far as you know? 19 A. Well, the document was a short 20 handwritten document that we were going to 21 continue our settlement communications, but that 22 they would be treated as mediation and 23 confidential. 24 Q. And without going into the substance, 25 was there any discussion of my client in that 86 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 meeting -- 2 A. No, her name was not mentioned. 3 Q. If you're willing to answer, I don't 4 know that you are; was there any discussion 5 concerning RICO, racketeering, during that 6 meeting? 7 A. I'm not going to discuss any 8 substance or subjects of the settlement 9 conference. 10 Q. Just to be clear on the record, in 11 case we have to file a motion or deal with it 12 otherwise; the substance of what was discussed at 13 the September 3rd, 2014 meeting, you are refusing 14 today to testify about the substance of that 15 meeting, correct? 16 A. Yes, based on the written agreement. 17 Q. I think you stated that you have 18 communicated with the Attorney General at least by 19 a letter, not with respect to my client, correct? 20 A. Yes, that's my recollection. 21 Q. Are you aware of anyone else that has 22 communicated with the Attorney General with 23 respect to any of the RICO defendants in this 24 case? 25 A. Other than what I testified to 87 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 previously, no. 2 Q. So there's a letter that you may or 3 may not have at this point? 4 A. A copy of a letter from someone on 5 behalf of the town in '14 or '15. 6 Q. Are you aware of any person other 7 than yourself that has communicated with any law 8 enforcement agency regarding any of the RICO 9 defendants? 10 MR. GOLDSTEIN: Form. 11 THE WITNESS: Am I allowed to reveal 12 anything that Mr. Richman told me? 13 Mr. Hochman? 14 MR. HOCHMAN: Pardon me? 15 THE WITNESS: Can I reveal what 16 Mr. Richman discussed with me? 17 MR. HOCHMAN: Yes. 18 THE WITNESS: I know that Mr. Richman 19 said he was having communications and I 20 don't... I think he said Statewide 21 Prosecutor. That's my best recollection. 22 BY MR. DE SOUZA: 23 Q. There's an e-mail that was produced 24 to me by the Town of Gulf Stream, it appears to be 25 from Mr. Richman to Mayor Morgan. Is that where 88 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 you're getting this recollection from? 2 A. I don't know. I really don't. I 3 seem to remember, it may be an oral 4 conversation... if you show me the e-mail. My 5 recollection is more of an oral statement. 6 MR. DE SOUZA: Let me go ahead and 7 mark this. 8 (Whereupon Exhibit Sweetapple-6, Copy 9 of E-mail dated April 6, 2015, was marked 10 for Identification.) 11 BY MR. DE SOUZA: 12 Q. Mr. Sweetapple, you have been handed 13 Exhibit 6 which is a copy of an e-mail that was 14 produced to us by the Town of Gulf Stream in this 15 litigation. It appears to be an e-mail from 16 Gerald Richman to Scott Morgan and a group of 17 others, including yourself, dated April 6, 2015. 18 Does that appear to be correct? 19 A. This is the first time I've seen this 20 e-mail again since April 2015. So, it doesn't 21 refresh my recollection. 22 My recollection comes from some 23 conversation with Mr. Richman regarding his 24 communication -- Aronberg I guess was the state 25 attorney, Statewide Prosecutor. He was handling 89 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 all that. 2 This was sent to me and, frankly, I'm 3 seeing it now and I don't remember having seen it 4 then. I'm sure it came to me and I looked at it 5 with 180 other e-mails that morning. 6 Q. Do you recall ever communicating with 7 the Statewide Prosecutor regarding the RICO 8 allegations? 9 A. No. 10 Q. Do you know who the Statewide 11 Prosecutor is that Mr. Richman is referring to in 12 this e-mail? 13 A. No. I knew who he was very well in 14 1982, he was a friend of mine. But I don't know 15 who he's been since then. 16 Q. Mr. Richman says: I will follow up 17 with Aronberg again tomorrow. 18 Actually referring to Dave Aronberg. 19 Is that your understanding of that? 20 A. That's what I would surmise from that 21 name. 22 Q. And Mr. Aronberg is the state 23 attorney for Palm Beach, correct? 24 A. Right. 25 Q. Have you communicated with 90 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Mr. Aronberg or his office regarding the RICO 2 allegations? 3 A. No. 4 Q. Do you know whether Mr. Richman has 5 actually communicated with Dave Aronberg regarding 6 the RICO allegations? 7 A. I don't. 8 Q. Do you recall any conversation with 9 Mr. Richman or anyone from his office about 10 communications with Dave Aronberg? 11 A. I have a vague recollection, a 12 recollection of Statewide Prosecutor Aronberg, the 13 town voting -- authorized that to be done. But I 14 don't have any recollection of any report from 15 Mr. Richman as to anything that was discussed -- 16 Q. Okay. 17 A. And frankly, in light of what I saw 18 in my investigation regarding Mr. O'Boyle and 19 Mr. Aronberg, I'd be very surprised that 20 Mr. Aronberg would not recuse himself from 21 anything dealing with Mr. O'Boyle, or would have. 22 That's a whole nother [sic] fiasco. 23 Q. Have you ever communicated with any 24 reporter or member of the media concerning 25 allegations underlying the RICO lawsuit? 91 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. Well, concerning CAFI or O'Boyle, I 2 would say yes. 3 When you use the terms, allegations 4 of the RICO lawsuit, yes, if you're saying facts 5 that are in there. 6 Q. Yes. 7 A. I have been called by one or more 8 reporters. 9 Q. I believe in your interrogatory 10 responses, which we received amended verified 11 responses yesterday, one such agency is listed as 12 the Florida Center For Investigative Reporting. 13 A. Right. 14 Q. Do you recall speaking to someone 15 from the Florida Center For Investigative 16 Reporting? 17 A. I do. I recall a reporter calling me 18 and asking me questions. I don't remember what he 19 asked me or what I said. I think it was on more 20 than one occasion. And I know there was an 21 article published after that. I don't think I was 22 quoted. 23 Q. Do you know whether during that 24 conversation or conversations with someone from 25 the Florida Center For Investigative Reporting, if 92 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 you mentioned that anyone had committed a crime? 2 A. I did not do that and would not do 3 that. 4 Q. Other than the Florida Center For 5 Investigative Reporting, do you recall speaking to 6 any other reporter or member of the media 7 regarding the RICO allegations? 8 A. I speak to a lot of reporters about a 9 lot of cases, and I've gone through my mind the 10 reporters and the papers that I've talked to, and 11 I don't believe so. 12 I never spoke to Alexandra Clough 13 from the Post. I didn't speak with The Review. 14 Coastal Star has never interviewed me. Sun 15 Sentinel. 16 I think the only -- I was interviewed 17 by The Florida Bar News when they wrote the 18 article on the new scam in February 2015. I think 19 that those -- there may have been two reporters, 20 may not have been the same reporter, I don't 21 remember, but those calls I think are the only 22 calls that I had with any reporter regarding 23 Mr. O'Boyle or any of the CAFI activities. 24 Q. Other than yourself, are you aware of 25 any other person communicating with a member of 93 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the media regarding the allegations underlying the 2 RICO lawsuit? 3 A. I remember seeing Mr. Richman's name 4 in articles. I remember seeing articles with his 5 name in it. I don't remember what paper it was or 6 what he said, but that's it. 7 Q. Did you ever communicate -- 8 A. I've seen Mr. Morgan's name in 9 articles. I've seen Mr. O'Hare and Mr. -- you're 10 talking about anybody. They've communicated with 11 letters to the editor and been quoted and Jonathan 12 O'Boyle, yes, I've seen those. 13 Q. Have you ever spoken with Mr. Richman 14 concerning his communications with the media? 15 A. No. 16 Q. Have you ever spoken with Mr. Morgan 17 concerning his communications with the media? 18 A. Yes. 19 Q. Were his communications with the 20 media with respect to the RICO allegations? 21 A. No, I don't know if he's spoken with 22 the media regarding RICO allegations. I only know 23 from the articles. I'd have to go back. 24 Q. Are you aware of any person, other 25 than in a court pleading or a caption somewhere, 94 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 other than yourself, that has stated that 2 Ms. DeMartini has committed a crime? 3 A. I think that Mr. Chandler in his 4 communications to me has certainly provided 5 statements of fact and evidence that would 6 strongly implicate Ms. DeMartini in a scheme to 7 defraud and to extort attorney's fees from victims 8 that were not in any way earned. 9 Q. Right now I'm limiting it to someone 10 that actually called her a criminal, or she's 11 committed a crime, made a statement like that, as 12 opposed to providing the facts underlying that 13 conclusion. Someone that actually stood up and 14 said, Ms. DeMartini is a criminal. Are you aware 15 of any person having done that, outside of a court 16 pleading or motion? 17 A. Well, Mr. Chandler did, when I spoke 18 to him, use the word criminal and fraudulent. He 19 was reporting to me, when I had a conversation 20 with him where I said, why are you calling me, you 21 need to have your own attorney. I'm calling you 22 to report criminal and fraudulent conduct. 23 And I was like, okay, you know, this 24 is a little bit of a surprise. 25 The only person that I would say used 95 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the word like criminal conduct would be 2 Mr. Chandler, and that's the only person I can 3 think of who actually said in any way is a 4 criminal, in that regard. 5 Q. Are you aware of any person, other 6 than in a court pleading or motion, that has 7 stated that Ms. DeMartini violated the RICO 8 statute? 9 MR. GOLDSTEIN: Form. 10 THE WITNESS: Not outside the scope 11 of the town's council and representatives who 12 were investigating, drafting, analyzing, 13 researching claims and identifying who the 14 Richman firm believed should be defendants in 15 the case. 16 BY MR. DE SOUZA: 17 Q. I will limit it to statements made to 18 third parties as we have defined that earlier. 19 A. I'm unaware of anyone even mentioning 20 Ms. DeMartini's name outside the scope of talking 21 to either the informant or the Gulf Stream team. 22 Q. The informant being Joel Chandler? 23 A. Right. 24 Q. Are you aware of any person outside a 25 court pleading or a motion making a statement to a 96 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 third party that any group of the RICO defendants 2 committed a crime? 3 MR. GOLDSTEIN: Form. 4 THE WITNESS: I'm unaware of any such 5 language. 6 BY MR. DE SOUZA: 7 Q. Are you aware of any statement made 8 by any person to a third party that any group of 9 the RICO defendants committed an act of 10 racketeering? 11 A. Outside the context of, as we've 12 discussed already, my statements regarding the 13 fact it was investigating, they were preparing -- 14 looking to prepare a complaint or trying to draft 15 a complaint or anything like that with the 16 opposing lawyer, no. 17 Q. Are you aware of any statement made 18 by any person to a third party, other than 19 yourself, in which any group of the RICO 20 defendants was accused of having committed a RICO 21 violation? 22 MR. GOLDSTEIN: Form. 23 THE WITNESS: Not outside the 24 parameters we've laid out. 25 BY MR. DE SOUZA: 97 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Are you aware of any statement made 2 by any person other than yourself to a third party 3 that any of the RICO defendants has committed an 4 act of extortion? 5 MR. GOLDSTEIN: Form. 6 THE WITNESS: Has that term been 7 used -- if it's been used in any of the media 8 reports? I'm not sure. I seem to remember 9 some... maybe the Bar News or -- I'm not sure 10 if I saw that word used in some of the 11 articles, maybe. I don't know. 12 BY MR. DE SOUZA: 13 Q. Does your firm have a written 14 engagement letter with the Town of Gulf Stream? 15 A. Other than the minutes of the meeting 16 and my letter confirming that I would undertake 17 the representation at a discounted rate, no. 18 Q. And the minutes of the meeting, 19 you're referring to what meeting? 20 A. There was a meeting of the council 21 where they agreed to hire my firm. 22 Q. Do you recall when that was? 23 A. April '14, I think. 24 Q. At this meeting, was there some vote 25 taken by the town commission to hire -- 98 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. I presume. I wasn't there. 2 Q. You weren't there at the meeting? 3 A. No. 4 Q. The engagement letter for your firm, 5 I haven't seen it. Does it describe what it is 6 that you were being retained to do for the Town of 7 Gulf Stream? 8 MR. GOLDSTEIN: Object to form. 9 Mischaracterizes previous testimony. 10 THE WITNESS: I think the minutes 11 would. I think my letter just confirms that 12 I'm undertaking representation, and whatever 13 it says, and then has my discounted rate. 14 Like one paragraph. 15 BY MR. DE SOUZA: 16 Q. Have you reviewed the minutes of that 17 meeting as to what the scope of your engagement 18 was? 19 A. Some time ago I did. 20 Q. Has the scope of your engagement -- 21 at the time that you were authorized and hired by 22 the Town of Gulf Stream, what was your 23 understanding of what the scope of your firm's 24 engagement was? 25 A. Special counsel to the town and to 99 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 consult and work with the town's attorneys with 2 regard to an onslaught of public records requests 3 that were being filed which were believed to be at 4 either specific behest or the actual request of 5 Martin O'Boyle and Christopher O'Hare, and their 6 agents or alteregos. 7 The scope did expand. If you want to 8 ask about that, I can go into that with you. 9 Q. Let me ask; at the time you were 10 retained, did you understand you were retained to 11 defend certain public records lawsuits that had 12 already been filed? 13 A. No. No. In fact, it wasn't, I don't 14 think, contemplated that there were -- that the 15 number of lawsuits that were going to be filed 16 were going to be limited. We believed it was 17 going to be accelerated. 18 My job was to find out what was going 19 on. It was a belief at the time that this was an 20 abuse of process type situation where O'Hare and 21 O'Boyle were working together to coerce the town 22 into granting permits and other -- and money under 23 the threat and actuality of barraging the town 24 again with public records requests, closing the 25 fax machine with 340 requests in a day, 80 a day 100 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 from O'Hare; that type of thing. 2 So I came in, I didn't know anything 3 about the O'Boyle law firm issue, and it was -- 4 basically I was going to be looking at whether or 5 not this was an abuse of process situation or some 6 type of abuse of the law, based on people just 7 trying to get approvals for zoning, which had been 8 denied. Then it expanded, obviously. 9 Q. In terms of the initial scope, is it 10 fair to say that the initial scope of your 11 representation was not limited to simply defending 12 public records lawsuits? 13 A. Well -- 14 Q. By that I mean, entering an 15 appearance and serving as counsel of record in 16 these public records lawsuits. The initial scope 17 was something broader -- 18 A. No one said, you're going to appear 19 in case A. 20 I was brought in because there was a 21 problem and I was brought in to consult with the 22 town, defend the town, assist the town's 23 attorneys, and finding out what was going on. And 24 at the time it was suspected that there was 25 another inflammation of an abuse which Mr. O'Boyle 101 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 had previously done that succeeded in bringing the 2 town to its knees and then writing a large check 3 to him, which was called attorney's fees, even 4 though it wasn't, he didn't have that much in 5 attorney's fees, and him getting his permit he 6 wanted. So I was brought in to deal with that 7 perceived situation, which would have involved 8 consulting and defending, say, a lawsuit that went 9 to trial, consulting with regard to requests that 10 came in, how to deal with them, you know. 11 That's what was anticipated 12 originally, then it did expand. 13 Q. How did it expand? 14 A. The first way it expanded was when I 15 started to obtain information that called into 16 question whether or not the O'Boyle law firm was 17 bona fide; whether the O'Boyle law firm even 18 existed at the time it filed complaints; whether 19 or not Jonathan O'Boyle was in Florida practicing 20 law without a license, which was something that 21 came from the transcript before Judge -- you may 22 have seen that whole thing in a motion, where he 23 dressed it down. And at that point I indicated to 24 the Mayor and the town manager that I wanted to 25 have authority to get costs to retain Gerry 102 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Richman, to consult with him, because he is a 2 former president of the Florida Bar and I had 3 worked extensively with the firm and that I had -- 4 while I had served as the vice chair of the 5 grievance committee for the Bar and chaired a few 6 arbitration committees in Dade County for years, 7 but I really was not familiar with the unlicensed 8 practice of law, and that I wanted to make sure 9 that anything the town was doing or saying was 10 researched and valid. And I was authorized I 11 think for $5,000 of his time. 12 And then coincidentally, in our 13 conversations, I learned that Mr. Richman was 14 defending a case brought by CAFI against a company 15 named the Wantman Group and I was learning about 16 hundreds of public records requests that were 17 being served on the town in the name of CAFI, but 18 coming from Commerce Group which was the same 19 address as the O'Boyle law firm, the same address 20 for CAFI, the same address for the Commerce Group, 21 and I recognized that CAFI was now really part of 22 this whole mix I was getting into and my antenna 23 went up. 24 So I started consulting with 25 Mr. Richman about CAFI and I got an earful about 103 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 what he had learned about CAFI at that point. And 2 I started to suspect that something -- I didn't 3 have any idea, but I suspected that something more 4 was going on and now it wasn't just Mr. O'Boyle 5 using entities that he had formed that already 6 existed and Mr. O'Hare using dozens of, 7 apparently, alteregos, but that an entity was 8 being formed and held out as being a 9 not-for-profit entity, like a de novo entity that 10 was being used as part of this public records 11 barrage on the town. 12 So, that was just a coincidence. 13 And then immediately when 14 Mr. Chandler called me I spoke with the Mayor and 15 told him exactly, you know, what happened, and I 16 asked permission to further consult with 17 Mr. Richman about the ramifications of what I had 18 been told and the chronology I had received. 19 And that was also a coincidence 20 because I became certified by the Florida Bar in 21 civil trial some time in the '90s, and ironically 22 the lecturer on RICO was none other than Gerald 23 Richman. 24 So I'm talking to Mr. Richman about 25 the unauthorized practice of law issues and CAFI 104 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 and what's going on and that's when I got 2 permission from the Mayor and town manager to 3 start consulting with Mr. Richman about the 4 ramifications of the chronology I had received and 5 that the nature of what I thought I was dealing 6 with was something quite different. 7 Q. In terms of the time line, you met 8 with Joel Chandler sometime in July 2014, correct? 9 A. I believe it was July 23rd, from my 10 review last night, if I'm not mistaken. 11 Q. As to your expanded scope of 12 representation of the Town of Gulf Stream, one of 13 the things you mentioned was that you asked for 14 authority to retain Gerald Richman to do some 15 initial investigatory work, correct? 16 A. No. I asked for permission to hire 17 Joel Chandler to consult with as an expert on the 18 topic of the unlicensed practice of law. 19 Q. You said Joel Chandler? 20 A. I mean Gerald Richman. I asked to be 21 able to hire him as an expert to consult with him. 22 Then after Joel Chandler contacted 23 me, I asked to expand his area of expertise that I 24 was consulting with him on, to the issues 25 involving the informant. 105 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. So chicken or egg situation. You met 2 with Joel Chandler on July 23rd; the asking for 3 authority to retain Richman as a consulting 4 expert, that comes before or after -- 5 A. Before. Well before. It was at the 6 time of the issues involving unlicensed practice 7 of law, which was the first issue that I was 8 confronted with when I looked at the involvement 9 of the alleged O'Boyle law firm. 10 Keep in mind the O'Boyle law firm was 11 formed at the end of '13 in Pennsylvania and 12 didn't become incorporated until maybe February, 13 after three or four lawsuits were filed under the 14 name of the O'Boyle law firm. 15 Q. And who did you ask for authority or 16 permission to retain Mr. Richman initially? 17 MR. GOLDSTEIN: Asked and answered. 18 THE WITNESS: I asked the town 19 manager and the Mayor if they would authorize 20 a cost, deposit $5,000 for me to consult with 21 an expert. 22 BY MR. DE SOUZA: 23 Q. And were you given that authority? 24 A. I was. 25 Q. By both the town manager and the 106 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Mayor? 2 A. Yes. 3 Well, I don't know who -- I don't 4 remember who I spoke to first. 5 I remember a statement that, 6 something about $10,000 maximum was all that the 7 manager could authorize or would authorize. 8 Something like that. I asked for five and I 9 remember something about a cap of ten. 10 Q. When we say town manager, are you 11 referring to Mr. Thrasher? 12 A. Yes. 13 Q. How was that authority communicated 14 to you? Was that in person, over the phone? 15 A. Just over the phone. 16 Q. And later, you sought additional 17 authority to have Mr. Richman do some further 18 investigative work, based on what you testified 19 to. 20 MR. GOLDSTEIN: Asked and answered. 21 THE WITNESS: No, not investigative 22 work. 23 Basically, I wanted to consult with 24 him and make him aware of what Mr. Chandler 25 had told me and the outline of facts. 107 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 I had received a letter from 2 Mr. Ring, I believe. 3 I did not give Mr. Richman the 4 Dropbox because I received a letter in the 5 interim that I responded to, but I did not 6 give Mr. Richman the actual documents. But I 7 had discussed with him the chronology. 8 So I was just basically saying to the 9 town, look, I'm already talking to him as an 10 expert and, coincidentally, I know this guy 11 is an expert in civil RICO, civil actions for 12 violation of the criminal laws, the civil 13 remedies for criminal acts statute. 14 And while I've litigated in those 15 areas, because I was representing the town 16 and because the allegations were very 17 serious, I thought, and were statewide, I 18 asked the Mayor and the city, the town 19 manager, if I could expand the scope of my 20 consultations with Mr. Richman and share 21 those details with him to get his input. 22 BY MR. DE SOUZA: 23 Q. So the answer was yes? 24 A. The answer was yes. 25 Q. Was that conveyed to you the same way 108 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 as the prior authorization, via telephone call 2 from one or the other? 3 A. I think that's all I did. I don't 4 believe I sent an e-mail. I don't think I did. 5 Q. Other than initially asking for 6 authority to retain Richman as a consulting expert 7 and then seeking further authority with respect to 8 Mr. Richman, has your scope of work for the town 9 expanded in any other way? 10 A. Well, I mean, as a function of the 11 facts I learned, obviously there were other 12 affirmative defenses, by you -- by virtue of the 13 fact that you filed suit alleging that documents 14 had been stolen, so I needed to file a dec action 15 in order to get a court to give me permission to 16 even give them to my client. I didn't give them 17 to my client. 18 So until Mr. O'Boyle produced to the 19 town some huge whatever you call it, with 20 terabytes on it, I held in confidence the 21 documents and was attempting to get the courts 22 to -- in any case where I wanted to use those 23 documents, I had to file a counterclaim so that I 24 made sure by the time of trial I could show that 25 these requests were made as part of a scheme to 109 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 defraud and to make it impossible for the town to 2 reasonably and timely respond to requests to 3 produce. 4 I don't know if you read this month's 5 Bar Journal article, but there's a Bar Journal 6 article that mentions Gulf Stream and talks about 7 the two forms of the scam. 8 So I was trying, you know, I had the 9 chronology and I had the sworn statement, but, you 10 know, it's like any other case; until you actually 11 produce the hard evidence, you say, that's just 12 one guy swearing to that. You had Mr. O'Boyle's 13 word and you had him swearing that he had nothing 14 at all to do with CAFI and you had Mr. Chandler 15 swearing that Mr. O'Boyle was running CAFI and had 16 all his minions doing his dirty work to enrich his 17 son's law firm, and I'm holding a pile of evidence 18 and you prevented me -- Mr. Ring prevented me, 19 ethically, from using it without a court decree 20 and I'm trying to get a court decree. 21 So that's what was going on. 22 Q. Were you part of the team, so to 23 speak, that performed the investigation prior to 24 the RICO lawsuit to prepare the final RICO 25 lawsuit -- 110 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. I wasn't ever hired to investigate a 2 RICO lawsuit. I was hired to get involved in 3 public records issues, and somebody threw a set of 4 facts and documents in my lap, and basically, the 5 way I got involved, was one of the first things 6 Gerry said was, listen, you know, you've 7 interviewed the witnesses, you've interviewed 8 Chandler; prepare a statement of facts, you know, 9 not identifying who defendants are or what theory. 10 Obviously there were a number of 11 theories that were available, RICO being one of 12 them. Could have sued for injunction saying it's 13 a violation of 817. Any number of things. That's 14 his call. 15 But he said, prepare a detailed 16 statement of facts. And that's where my initial 17 involvement came. And then obviously, as I 18 learned more facts, which I kept learning more 19 facts, the statement of facts was supplemented. 20 And then I was involved, obviously, 21 in meeting with them and going over the drafting 22 and answering their questions about, you know, 23 what did O'Hare say, what did O'Boyle testify to, 24 what did, you know, those types of -- they 25 interviewed me and debriefed me just like anybody 111 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 else. 2 Q. The concept of RICO, we're going to 3 pursue a RICO claim against this group of 4 defendants; as far as you recall, when was that 5 first aired? 6 A. Early on. I think even before I was 7 hired, when I first came on board, I remember 8 questions; what's going on here, is this some kind 9 of scheme to shake down the town? What's going on 10 with all these people? This is -- CAFI is doing 11 this. 12 And I remember discussions early on 13 about whether or not this was abuse of process, 14 malicious prosecution, a fraudulent scheme, 15 racketeering enterprise. This is totally 16 abnormal. 17 So I remember discussions about that 18 even before Chandler, I think. 19 Q. Who would have been involved, to your 20 recollection, in discussions about whether this 21 alleged conduct constituted racketeering or a 22 violation of RICO? 23 MR. GOLDSTEIN: Form. 24 THE WITNESS: Well, another 25 coincidence. 112 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 My recollection is that Joanne 2 O'Connor's associate was Gerald Richman's 3 daughter. And I remember a discussion early 4 on with her and Joanne where she was raising 5 the issue of, was this an abuse of process or 6 was this a criminal enterprise, was this a 7 scheme to defraud, why are there all these 8 crazy names and different companies and why 9 are we getting over a hundred requests from 10 CAFI. The O'Boyle law firm is representing 11 everybody, it's all being run out of the same 12 place. 13 So I remember RICO being tossed in 14 the mix of what they were analyzing even 15 before I -- coming on scene and hearing all 16 this and thinking, is this going to be more 17 than just public records litigation? Because 18 when I was hired, I didn't know what CAFI 19 was. I knew that there was a massive amount 20 of public records requests, but I really 21 didn't have any detail at all. 22 BY MR. DE SOUZA: 23 Q. Other than taking a shot at drafting 24 the initial statement of facts to be used in the 25 RICO complaint, did you have any other role in 113 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 drafting that -- 2 A. I redrafted. I met with them. They 3 wanted -- there were things, like with regard to 4 Mr. O'Hare, I had off-the-record communications 5 with Mr. Chandler after the debriefing, and wanted 6 to know Mr. O'Hare's involvement before I talked 7 to him separately about settling with him. And 8 they wanted to know all about that, anything 9 that -- anything I was involved in. So as they 10 were researching and writing and drafting, they 11 would give me sections or, you know, what happened 12 here, what did this person do, what do you know 13 about this, tell me about the O'Boyle law firm. 14 So I met with them, I'm sure I met 15 two or three times at their offices. I'm sure 16 that I redrafted sections and I discussed -- 17 whatever Gerry asked me to do, you know, I did. 18 Q. Did you or anyone from your firm do 19 any legal research regarding the viability of the 20 RICO claim? 21 A. I think, I think I had somebody do 22 research on something, and I don't remember what 23 it was. 24 I think, if I'm not mistaken, I had a 25 discussion with Gerry about the fact that, 114 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 shouldn't this be brought in State Court. This is 2 a state issue, it's state interests. And he said 3 no, the litigation privilege would bar it. And I 4 said why would the litigation bar it if it's 5 fraudulent or criminal conduct being -- at the end 6 of -- it's not the filing of the lawsuit, it's the 7 demanding and extorting legal fees that were 8 incurred and defrauding and stating these fees 9 were incurred. 10 He said, listen, Levin is so broad 11 that I wouldn't want to file in State Court. 12 Levin I think will ultimately be narrowed. But 13 like all laws, when the Supreme Court comes out 14 with an opinion, it's broad, and later people, 15 like they're doing now, is malicious prosecution 16 barred -- if you read Levin, if you do anything 17 through a lawyer, you can do it. 18 And I remember saying, well, this is 19 not a real plaintiff. What if you have a fake 20 plaintiff or a fake crash. He said, Levin, in 21 State Court, you're dead. And I'm recommending to 22 the client that they file a federal RICO. 23 I remember thinking to myself, he's 24 the expert, but I got my doubts about that, that 25 doesn't make sense to me. You go to federal 115 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 court -- I was always looking at 817 as being the 2 predicate act. I thought this was a classic 3 scheme to defraud, using lawyers and lawsuits to 4 get to the ultimate fraud and extortion. 5 So I remember -- I don't do my own 6 legal research, so I know I didn't do it. I can 7 tell you that. I decided in the University of 8 Florida I would not do the legal research and that 9 people would do it better than me, because back 10 then you had to not have ADD, which I have, you 11 have to sit there and Shepardize and read for four 12 hours, and I said, this is not me. 13 I know someone else did it. I don't 14 remember who I had do it. It would have been an 15 associate partner or paralegal. 16 I remember thinking, I just think 17 this is a state RICO case, you know? I remember 18 that research. And I don't think I argued with 19 him because it wasn't my place. 20 I questioned, why are you doing this 21 in Federal Court? I remember him saying, under 22 the precedents and some other circuit, you know, 23 the 11th has this rule, the 5th has this, and I 24 think the law is going to go to where this is -- 25 if they're in the 11th they're going to recognize 116 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 that even in litigation you can't extort and you 2 can't say someone is public not-for-profit when 3 they're not, when it's just the lawyer. 4 If there's anything else I 5 researched... I'm trying to think if there's any 6 other thing I discussed with him. 7 When speaking with Scott, he's a 8 lawyer, so I would -- he would ask me what I 9 thought of Richman's view or that case that 10 Richman cited. He would always bounce stuff off 11 of me to see whether or not I agreed with Richman. 12 I would sometimes have somebody look 13 at a legal issue and say, Scott, I'm not the 14 expert, but everything I see, it looks like Gerry 15 knows what he's doing. I'm comfortable. You 16 know? So I would get involved in that way. 17 But basically all the major research, 18 all the legal theories, all the statements of the 19 claims, the parties that were included, that was 20 based on information I gave them. But that wasn't 21 my place. 22 Q. Do you know if there was ever any 23 memos or e-mails prepared by any of the lawyers 24 involved in addressing whether the RICO claim 25 would be successful or the viability of the RICO 117 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 claim? 2 A. I remember seeing e-mails talking 3 about this case, that case, you know, what the 4 anticipated defense would be, whether or not -- I 5 remember Gerry saying the litigation privilege in 6 the State Court was not where these claims would 7 be recognized, but the Federal Court would open up 8 to them. 9 I believe there were memos. I'm sure 10 I saw memos, e-mails going back and forth where 11 Eric what's his name, Sodhi, S-o-d-h-i, I met with 12 him twice when I was at their offices, set up a 13 conference room and they talked. And I think I 14 may have seen an e-mail between Eric and Gerry 15 from time to time, or a memo. 16 I don't have a specific recollection, 17 but I recall things like that. 18 Q. Are you aware that your attorney in 19 this case has served a Notice of Deposition, I 20 suppose a subpoena, as well, on Jonathan O'Boyle 21 for deposition testimony? 22 A. Other than -- other than my attorney 23 telling me something -- 24 MR. GOLDSTEIN: I'm going to 25 object -- 118 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MR. DE SOUZA: 2 Q. Have you seen a Notice of -- 3 MR. GOLDSTEIN: I'm objecting to your 4 last question to the extent you're inquiring 5 into communications between my client and me. 6 THE WITNESS: To answer your 7 corrected question, no, I have not seen any 8 notice or subpoena regarding Jonathan 9 O'Boyle. 10 BY MR. DE SOUZA: 11 Q. Do you believe Jonathan O'Boyle has 12 some information or knowledge relevant to the 13 claims or defenses against you in this litigation? 14 So, the plaintiff's slander claim against you; do 15 you believe Jonathan O'Boyle is somehow relevant 16 to that claim? 17 MR. GOLDSTEIN: I object to the 18 extent that any of those discussions or 19 understandings invoke any communications he's 20 had with his counsel. 21 MR. DE SOUZA: I'm only asking for 22 his own understanding. 23 THE WITNESS: You're asking for my 24 legal conclusion and my legal opinion on 25 relevance? On relevance? 119 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 BY MR. DE SOUZA: 2 Q. No. 3 You want the deposition of Jonathan 4 O'Boyle. Your counsel has submitted a Notice of 5 Deposition on your behalf. So presumably you 6 believe Jonathan O'Boyle is somehow relevant to 7 this case. 8 A. First of all, I'll discuss how I want 9 to defend my case with my attorney. I'll defer to 10 his advice because I recognize that when I'm the 11 client, even though it's very difficult, I should 12 behave as a client. And I'm certainly not going 13 to project my idea on what's relevant or not on 14 his desire to take discovery of what could lead to 15 admissible evidence or not. 16 I think that Jonathan O'Boyle is 17 extremely involved with Denise DeMartini and will 18 be able to provide evidence as to her activities, 19 her credibility, her running the law firm, her 20 running CAFI, her knowledge of the windfall 21 scheme, her financial remuneration for 22 participating in the windfall scheme. 23 So I'm going to defer to my attorney 24 who I'm very impressed with and I'm just playing 25 my role in the case, which is to testify 120 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 truthfully to you, testify truthfully in court, 2 and let him make whatever legal arguments he needs 3 to make and take whatever discovery he needs to 4 take. 5 Q. Have you ever communicated with 6 Jonathan O'Boyle? 7 A. Yes, I have. 8 Q. Have you ever stated to Jonathan 9 O'Boyle that Denise DeMartini has committed any 10 crime, whether generally or a particular crime? 11 A. I've never spoken to Jonathan O'Boyle 12 about the facts of -- involving Denise DeMartini 13 or his involvement with Denise DeMartini. 14 MR. DE SOUZA: I'm going to mark this 15 as the next exhibit, Exhibit 7. 16 (Whereupon Exhibit Sweetapple-7, Copy 17 of Defendant Robert A. Sweetapple's Rule 26 18 Disclosures, was marked for Identification.) 19 MR. DE SOUZA: Exhibit 7 is a copy of 20 Defendant Robert A. Sweetapple's Rule 26 21 disclosures served in this case. 22 BY MR. DE SOUZA: 23 Q. Have you ever seen these initial 24 disclosures before today, Mr. Sweetapple? 25 A. They were e-mailed to me. I don't 121 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 know that I've studied them, frankly. I don't 2 think I read these. 3 Q. There's a list of names in these 4 initial disclosures, as required under the rules, 5 of people that may have information relevant or to 6 be used to support the parties' claims or 7 defenses. 8 Can you see it starts with Martin 9 O'Boyle and it goes some 24 specific individuals, 10 entities; do you see that? 11 A. Yes, I do. 12 MR. GOLDSTEIN: The documents speak 13 for themselves. 14 MR. DE SOUZA: But I really want to 15 hear from Mr. Sweetapple. Is that okay? 16 MR. GOLDSTEIN: I'm just saying, the 17 document speaks for itself. If there's a 18 question pending, you can ask the question. 19 MR. DE SOUZA: Thank you. 20 BY MR. DE SOUZA: 21 Q. Looking at the list of names, 1 22 through 24, are there any individuals or entities 23 identified that you made a statement to that 24 Denise DeMartini committed any crime? 25 MR. GOLDSTEIN: Asked and answered. 122 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 MR. DE SOUZA: That's great. He can 2 answer it again. 3 THE WITNESS: Just note that, 4 obviously, to the extent that some people on 5 here are co-counsel and clients, so I'm not 6 going to change the parameters of my prior 7 answer. Everyone else, no. 8 BY MR. DE SOUZA: 9 Q. We exclude yourself, which is number 10 3. 11 A. If you ask me what I thought, you 12 know, I don't talk to myself that often. 13 Sometimes I do. 14 Q. I don't consider you to be a third 15 party, so we'll scratch you off. 16 A. Good. 17 I have a couple different 18 personalities, according to my wife, but I don't 19 think it's quite a third party yet. 20 Q. Scott Morgan is listed as number 4, 21 we can cross him off as not being a third party. 22 A. Right. 23 You've asked me about Jonathan. 24 Q. I've asked you about Jonathan. 25 What about William Thrasher; do you 123 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 consider him to be a third party or a client? 2 A. Client. 3 Q. We can scratch off number 12? 4 A. 7 is Mr. Ring. 5 I've written to Mr. Ring and told him 6 that I was not returning the CAFI documents 7 because I... I think I said I believe that they 8 were evidence of fraudulent or criminal scheme, 9 and listed a number of reasons why I wasn't. So I 10 communicated to him a legal theory. 11 Q. I'm just trying to identify the 12 people on this list that you consider to be not 13 third parties. 14 A. Oh, I'm sorry. I thought you were 15 going in order. 16 Q. I just want to scratch off the ones 17 that are not third party. 18 Robert Ganger, number 13. 19 A. And Thrasher, 12. 20 Q. How about Ganger, 13? 21 A. 13. 22 And is Donna White a councilwoman? 23 Q. According to the initial disclosures 24 she's listed as a commissioner for -- 25 A. Right, so we would have to scratch 124 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 her off. 2 15, 16, 17, 18, 22, 23. 3 Those are the ones that I would 4 consider that I have a fiduciary obligation to. 5 Q. So without delving into conversations 6 with any of the ones that we have scratched off, 7 the remaining names on this list, have you stated 8 to any of the remaining names on this list that 9 Ms. DeMartini has committed a crime? 10 A. No. 11 Q. Have you stated to any of the 12 remaining names on this list that any group of 13 people or individuals, including Ms. DeMartini, 14 has committed a crime? 15 A. No. 16 Q. Have you stated to any of the 17 remaining names on this list that Ms. DeMartini or 18 any group of people, including Ms. DeMartini, has 19 committed a violation of the RICO statute? 20 A. No. 21 MR. DE SOUZA: I'm going to mark as 22 Exhibit 8 Defendant Robert A. Sweetapple's 23 Response to Plaintiff's First Request for 24 Admissions. 25 (Whereupon Exhibit Sweetapple-8, 125 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Defendant Robert A. Sweetapple's Response to 2 Plaintiff's First Request for Admissions, 3 was marked for Identification.) 4 BY MR. DE SOUZA: 5 Q. Exhibit 8 is a document served on me 6 by your counsel in this case. It is your response 7 to plaintiff's first request for admissions. 8 Have you ever seen this document 9 before? 10 A. I have. 11 Q. Were you consulted in the preparation 12 of the responses to these requests for admissions? 13 A. I believe that calls for privilege, 14 but I have reviewed these. 15 MR. GOLDSTEIN: To the extent you can 16 answer without invading any attorney/client 17 communication. 18 THE WITNESS: I've discussed all 19 filings with my lawyer before they're filed. 20 BY MR. DE SOUZA: 21 Q. Turn to the actual responses. Look 22 at request for admission number one. 23 Request for admission number one asks 24 you to admit that you were retained by Gulf Stream 25 to assist in the defense of certain public records 126 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 lawsuits filed by Martin E. O'Boyle and/or 2 Christopher O'Hare. 3 The response is an objection on the 4 basis that it is compound. 5 If I asked you, admit that you were 6 retained or that your firm was retained by the 7 Town of Gulf Stream to assist in the defense of 8 certain public records lawsuits filed by Martin 9 O'Boyle, is that a true statement? 10 MR. GOLDSTEIN: Asked and answered. 11 THE WITNESS: I think that's -- I 12 think it would be a legal conclusion. You'd 13 have to look at the minutes and that would be 14 part of the scope of why I was hired. I was 15 not specifically hired to handle a named case 16 or a numbered case. 17 BY MR. DE SOUZA: 18 Q. And was part of the scope that you 19 were hired to assist in the defense of certain 20 public records lawsuits filed by Christopher 21 O'Hare? 22 MR. GOLDSTEIN: Asked and answered. 23 THE WITNESS: It was contemplated I 24 would be doing that. 25 BY MR. DE SOUZA: 127 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. The abbreviated letter you prepared 2 upon your initial engagement, was that signed by 3 any representative of Gulf Stream? 4 A. No. 5 Q. It's just a letter that you sent to 6 someone, and that was sent to the town? 7 A. Yes. 8 MR. GOLDSTEIN: Asked and answered. 9 BY MR. DE SOUZA: 10 Q. The initial letter that you sent to 11 the town as part of your initial engagement by the 12 town, is Denise DeMartini's name mentioned 13 anywhere in that letter? 14 A. No. 15 Q. As far as you know, the minutes of 16 the meeting that approved your firm's retention, 17 is Denise DeMartini's name mentioned anywhere in 18 those minutes? 19 A. I don't believe so. 20 Q. As you sit here today, are you aware 21 of any public records requests sent to Gulf Stream 22 where the requester was identified as being Denise 23 DeMartini? 24 A. I believe I have seen that in the 25 logs, yes. 128 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Are you aware how many of those 2 requests you have seen? 3 A. I'd have to go back and look at the 4 logs. 5 Q. And when you said you believe so, do 6 you mean Denise DeMartini individually or Denise 7 DeMartini on behalf of some entity such as CAFI or 8 Commerce Group? 9 A. I'd have to -- I remember seeing her 10 name, but I didn't isolate what capacity and how 11 many times. That wasn't something I focused on. 12 Q. Other than this case, are you aware 13 of any lawsuit against Gulf Stream in which Denise 14 DeMartini is a named plaintiff? 15 A. In terms of public records cases, no. 16 And I don't know -- other cases, I wouldn't be 17 privy to. 18 Q. Just what you're aware of. 19 A. I'm not aware of any. 20 MR. GOLDSTEIN: Other than this case, 21 obviously. 22 MR. DE SOUZA: Other than this case. 23 BY MR. DE SOUZA: 24 Q. Other than drafting the certain 25 portions of the statement of facts in the RICO 129 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 complaint, did you participate in drafting any 2 other section of that complaint? 3 MR. GOLDSTEIN: Asked and answered. 4 THE WITNESS: I don't believe so. 5 The complaint that was filed was all prepared 6 by Eric. 7 BY MR. DE SOUZA: 8 Q. Turn to request number eight on this 9 request for admissions. 10 It asks to admit that Joel Chandler 11 told you not to name Christopher O'Hare as a 12 defendant in the RICO lawsuit. 13 The response is, denied as phrased. 14 My question is; what's wrong with the 15 phrasing that does not allow you to admit or deny 16 this? 17 A. I never spoke to Mr. Chandler about 18 not naming or naming Christopher O'Hare. I became 19 aware of Mr. Chandler's attempt to cover for 20 Mr. O'Hare through a letter he wrote or a letter 21 to the editor or something Mr. O'Hare had read 22 into the record at a meeting. It wasn't any 23 direct communications with Mr. Chandler. 24 But I had already formed my own 25 opinions about Mr. O'Hare's involvement based on 130 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 my investigation and what I had already been told, 2 and I clearly saw Mr. Chandler's statements as an 3 attempt to cover for Mr. O'Hare and protect him. 4 I can explain that to you if you 5 want, or I can't if you don't want. 6 Q. In any of your communications with 7 Joel Chandler, do you recall him ever using the 8 word RICO? 9 A. Maybe speaking back to me or if I 10 said, we're investigating filing a civil RICO 11 case, he may have used the word back in that 12 conversation, but I don't have a specific 13 recollection of him saying, RICO. I mean, he's 14 not a lawyer. 15 Q. Do you have a specific recollection 16 of Mr. Chandler ever using the word racketeering 17 in any of your communications with him? 18 A. No. 19 Q. Are you aware of any monies that were 20 ever paid to Ms. DeMartini as a result of her 21 participation in the alleged RICO enterprise? 22 A. My understanding, although I have not 23 seen any documentation, is that her earnings 24 increased considerably during the time period that 25 she was running the law firm, serving as a CAFI 131 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 director and involved in the facts alleged in the 2 complaint. 3 Q. Are you aware of any State Court case 4 in which Denise DeMartini was named as a 5 counter-defendant or a third party defendant by 6 the Town of Gulf Stream? 7 A. I am. In declaratory judgment 8 actions attempting to get permission to publish 9 documents that were alleged by you as counsel for 10 CAFI to be private, confidential records that were 11 owned by CAFI at the time that Ms. DeMartini was 12 allegedly administering that entity. 13 Q. If you know, who was the counsel that 14 filed these counterclaims or third party 15 complaints in which Ms. DeMartini was named -- 16 MR. GOLDSTEIN: Form -- 17 THE WITNESS: I'd have to look at 18 them -- 19 MR. GOLDSTEIN: Object to form. 20 THE WITNESS: I don't know if it was 21 the same for all of them. 22 Jones Foster or my firm or both would 23 have filed those, in any case where we were 24 seeking to or thought we would need to get 25 those records into evidence. We couldn't 132 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 wait till the day of trial because you had 2 another case pending that had not been 3 adjudicated, so the court that actually 4 supervised the admission of evidence would 5 have to make a decision if we didn't have 6 adjudication. 7 BY MR. DE SOUZA: 8 Q. Do you have an understanding of how 9 many cases or counterclaims or third party 10 complaints were filed by the Town of Gulf Stream 11 in which Denise DeMartini was named as a 12 counter-defendant? 13 MR. GOLDSTEIN: Object to form. 14 THE WITNESS: Anywhere we anticipated 15 that we would need to put in the records that 16 she was or she had directed you, as the CAFI 17 agent, to keep from ever going into evidence, 18 so the number, I seem to remember something I 19 saw you wrote, six or eight. 20 That's my best guess or best 21 recollection. 22 BY MR. DE SOUZA: 23 Q. Do you know whether all of those 24 counterclaims, third party complaints were 25 actually served on Ms. DeMartini? 133 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. I don't believe that we served ones 2 after there was a summary judgment from Judge 3 Oftedal where he indicated he was not going to go 4 into any of those issues, in the public records 5 case. 6 We did not serve any after that 7 because we knew we were going to appeal that 8 summary judgment when it became a final judgment, 9 which just happened. Or if the underlying case 10 was not being prosecuted to where we were going to 11 need the documents, we didn't serve them until -- 12 we didn't want to create legal work and a 13 requirement for answers and pleadings until we saw 14 that, pre-summary judgment, till we saw that we 15 were going to need to use those records in that 16 case. 17 Q. Do you know if any effort was ever 18 made to notify Ms. DeMartini that she had been 19 sued in a number of cases that had not been served 20 on her? 21 MR. GOLDSTEIN: Object to form. 22 THE WITNESS: She had -- she was 23 running the O'Boyle law firm and the O'Boyle 24 law firm was counsel in that -- many of those 25 cases. 134 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Mr. Roeder was counsel. Mr. Roeder 2 was filing dozens and dozens of requests on 3 behalf of Mr. O'Hare and he was in 4 communication with her, I presume. And you 5 were counsel in the CAFI case. I presume she 6 was talking to any number of attorneys, but 7 she would not need to respond unless we 8 elected to have the court hear the 9 declaratory judgment action in that case, if 10 and when we were going to be faced with the 11 need to put the documents that you wanted to 12 keep us desperately from ever having the 13 court see introduced in evidence. 14 Now, of course we made all of those 15 records public records and the court and 16 anyone else that has an opportunity, 17 including any juries, would be able to see 18 the absolute extent of your client's 19 involvement in the schemes and the fraud, and 20 will I think have little doubt as to why I 21 was trying to get those records into evidence 22 in those cases and to overcome the roadblock 23 you were imposing for this enterprise. 24 BY MR. DE SOUZA: 25 Q. Other than an assumption that Lou 135 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Roeder, myself, some representative of the O'Boyle 2 law firm, informed Ms. DeMartini about the filing 3 of these lawsuits, my question relates solely to 4 efforts by Gulf Stream to inform her that these 5 lawsuits had been filed and were pending against 6 her -- 7 A. There's a legal duty to do that by 8 way of filing, by serving. You have 180 days to 9 serve someone. If you decide you need to have 10 them respond, and I -- I believe there were a 11 number of lawsuits where we decided not to serve 12 her and I gave the reason why pre-summary judgment 13 we didn't serve her and why post-judgment we 14 didn't serve her, and what we decided to do was 15 dismiss those without prejudice until such time as 16 we have the 4th District determine whether or not 17 we can proceed with the counterclaim. 18 Q. Do you know, as you sit here today, 19 how many lawsuits -- how many of these 20 counterclaims, third party complaints were not 21 served on -- 22 A. I know that there were about 40 cases 23 pending where we believed we would need these 24 records, and we only filed the counterclaim in I 25 think six or eight. 136 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 What happened was we tried to have 2 everything consolidated before Judge Oftedal, so 3 there would only be one counterclaim, and we did 4 not want to have to bring town officials to 40 5 different trials, but your clients insisted that 6 these be 40 separate trials, so we would have to 7 have 40 different occasions where the clerks and 8 witnesses come and we would have to file 40 9 different counterclaims in order to get the 10 records that you were so desperately trying to 11 keep secret. 12 But had the original order that was 13 presented by the judge been followed, this would 14 have all been summarily decided one time with one 15 counterclaim, which is what I had an order 16 providing would occur, but your team decided to 17 resist that and got Judge Oftedal to reissue all 18 of the cases to all the divisions they had come 19 from, which now necessitated us, instead of having 20 one counterclaim to introduce these documents, to 21 have multiple ones. 22 Q. I believe my arithmetic is correct, 23 but there are about 20 defendants named in the 24 RICO class action complaint. 25 A. I'd have to see it. 137 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. I'll let you take a look. 2 I'm not going to introduce it as an 3 exhibit, but I've handed you what I'll represent 4 is the class action RICO complaint that was filed 5 by the Town of Gulf Stream. 6 Do you agree with me that there are 7 approximately 20 different defendants identified 8 in the caption on the RICO complaint? 9 A. I'm not going to add them up. 10 Whatever it is, it is. It's multiple. 11 Q. Several. 12 A. More than several. 13 Q. Was any particular person or law firm 14 tasked with investigating who would be a proper 15 defendant in the RICO lawsuit? 16 MR. GOLDSTEIN: Asked and answered. 17 BY MR. DE SOUZA: 18 Q. You can answer again. 19 To your knowledge, was any particular 20 attorney or law firm tasked with investigating who 21 should be named or who would be an appropriate 22 defendant in the RICO lawsuit? 23 A. The lawsuit was filed by the Richman 24 Greer, PA law firm, and I know from my experience 25 that when I sign a pleading or allow my firm name 138 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 to be in a pleading, I am tasked with the role of 2 determining who ultimately are the proper 3 defendants and whether or not the claims can be 4 maintained in good faith. 5 So, I presume the lawyers from 6 Richman Greer that worked on the case, but as to 7 which one, I wouldn't -- 8 Q. Again, without assuming or 9 presumptions -- 10 A. I don't know. 11 Q. You don't know. 12 A. I should have answered the question 13 that way. 14 Q. I should talk to someone at the 15 Richman Greer law firm about that. 16 A. Yeah. 17 Q. As far as you know, no one from your 18 law firm made any sort of legal conclusions that 19 these are the 20 correct defendants for the RICO 20 lawsuit, correct? 21 MR. GOLDSTEIN: Object to form. 22 THE WITNESS: I don't believe I was 23 asked who -- is this the proper group of 24 defendants. 25 BY MR. DE SOUZA: 139 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Are you aware of any discussions 2 concerning whether Joel Chandler should have been 3 included in the list of RICO defendants? 4 A. I seem to recall some discussion of 5 that. I don't know who with or when. 6 Q. What do you recall about those 7 conversations? 8 A. I remember there was some discussion, 9 hey, Joel was involved, up until the time he 10 extricated himself, he blew the whistle, but he's 11 still involved, should he be a defendant. I 12 remember hearing something like that. 13 Q. Do you recall there ever being any 14 concern expressed -- strike that. 15 As far as you know, was there ever 16 any effort to keep Joel Chandler out of the mix of 17 defendants, to find a way to not name him as a 18 defendant? 19 A. No, there was no -- I was not aware 20 of any oral or written agreement to that effect. 21 Q. Do you know who made the decision to 22 name Denise DeMartini as a defendant in the RICO 23 lawsuit? 24 MR. GOLDSTEIN: Asked and answered. 25 THE WITNESS: The ultimate decision 140 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 as to who to name as a defendant was made by 2 the Richman Greer law firm based on all the 3 information they had. 4 BY MR. DE SOUZA: 5 Q. Do you know why Ms. DeMartini was 6 included as a defendant? 7 A. I have an opinion. Do you want my 8 opinion? 9 Q. No. I only want to know if you know 10 why she was included. 11 A. I don't know why. I only have a 12 legal opinion. 13 Q. Okay. What's your opinion? 14 A. My opinion is that Ms. DeMartini was 15 Mr. O'Boyle's right-hand person with regard to the 16 scheme and that it occurred at her direction and 17 with her knowledge and she profited from it. And 18 the e-mails pretty much bear that out, as far as I 19 can tell. 20 Q. And you're basing your legal opinion, 21 I assume, partially on statements made by Joel 22 Chandler. 23 A. Yes. 24 Q. I assume you're basing it partially 25 on the transcript or the formal court reporter's 141 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 statement of Joel Chandler's interview. 2 A. Yes. 3 Q. I assume you're basing it partially 4 on documents that you received from Mr. Chandler 5 through this Dropbox -- 6 A. Yes. 7 Q. I assume you're basing it partially 8 on corporate documents for CAFI that have been 9 produced in this case that were available on 10 Sunbiz? 11 A. Yes. 12 Q. Are there any other documents, 13 besides what we have just covered, that you're 14 basing that legal opinion on? 15 A. Yes. The memorandum that Mr. O'Boyle 16 sent to his tax lawyer, Mr. Tweel, that he gave a 17 copy of to Mr. Chandler. 18 Q. What does that memorandum concern? 19 A. CAFI and the entire scheme. 20 Have you seen it? 21 Q. As we talk in the abyss, I wouldn't 22 know. 23 A. Are we going to break for lunch? How 24 much time do you have? Because I am starving. 25 Q. We're pretty close. We're towards 142 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 the end. 2 A. How about I get a little water and 3 candy so I can get a little sugar. 4 MR. HOCHMAN: Let's accommodate the 5 witness. 6 (Whereupon a discussion was held off 7 the record.) 8 (Whereupon a recess was taken.) 9 BY MR. DE SOUZA: 10 Q. Are you aware of any invoices from 11 your firm that reflect time spent assessing 12 whether Denise DeMartini would be a proper 13 defendant in the RICO lawsuit? 14 A. I never had any doubt that she would 15 be. I mean, to me she was key. I can't even 16 imagine... she and -- to me she's a key, key 17 player in a scheme to defraud and extort. 18 Q. Speaking as Gulf Stream's 30(b)(6) 19 designee, did Gulf Stream believe that 20 Ms. DeMartini was part of the alleged Rico 21 Enterprise? 22 A. Absolutely. From what I concluded 23 and everyone else around concluded, I would say 24 yes. There was no doubt or question about it. 25 Q. Speaking as Gulf Stream's 30(b)(6) 143 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 designee, did Gulf Stream believe that 2 Ms. DeMartini was participating in the making of 3 records requests to Gulf Stream? 4 A. Yes, but that wasn't the concern. 5 Nobody was concerned about making a public records 6 request. 7 The concern was that she was 8 operating CAFI and the O'Boyle law firm for the 9 purpose of extorting legal fees, by artifice or 10 lie, from Gulf Stream, and had successfully done 11 it, based on the e-mails we obtained from other 12 governments. 13 Q. Gulf Stream believed that 14 Ms. DeMartini was operating CAFI? I believe 15 that's what you just said. 16 A. I believe the e-mail showed she was, 17 in conjunction with Mr. O'Boyle and the law firm. 18 Q. To more accurately state it. Gulf 19 Stream believed that Ms. DeMartini, in conjunction 20 with Martin O'Boyle and the O'Boyle law firm, was 21 operating CAFI? 22 A. Yes. 23 MR. GOLDSTEIN: Object to form. 24 THE WITNESS: I'm going to need to 25 take a break to eat because I'm definitely 144 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 getting dehydrated and starving. 2 How much longer are you going to be? 3 BY MR. DE SOUZA: 4 Q. If I tell you we're ten minutes 5 out... 6 A. Okay. 7 Q. We can take a break, but I think I've 8 got ten minutes more? 9 MR. COHEN: Does anyone else in here 10 have questions? 11 I'm all for -- 12 MR. DE SOUZA: Let's go off the 13 record. 14 (Whereupon a discussion was held off 15 the record.) 16 BY MR. DE SOUZA: 17 Q. Did Gulf Stream believe that 18 Ms. DeMartini, in conjunction with Mr. O'Boyle, 19 was running the O'Boyle law firm? 20 A. Yes. 21 Q. Did Gulf Stream believe that 22 Ms. DeMartini was one of the organizers of the 23 alleged RICO enterprise? 24 A. Yes. 25 Q. Did Gulf Stream believe that 145 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Ms. DeMartini was participating in the filing of 2 public records lawsuits against Gulf Stream? 3 A. Yes. 4 Q. Are you aware of any discussion ever 5 occurring about the RICO lawsuit being used to 6 stop the filing of public records lawsuits against 7 Gulf Stream? 8 A. No. I did read comments in the 9 paper. 10 Q. Comments by who? 11 A. I don't remember. 12 Q. Do you know if it was by a 13 representative of Gulf Stream? 14 A. I thought Gerry maybe. I don't 15 remember. I remember seeing something in the 16 paper. 17 Q. Are you aware of any discussion about 18 the State Court counterclaims being used as a 19 means to stop the filing of public records 20 lawsuits? 21 A. No. 22 Q. As far as you're aware, was that a 23 part of Gulf Stream's motive in filing the RICO 24 lawsuit, to stop the filing of these public 25 records lawsuits? 146 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. No. It was to stop the extortion and 2 prevent the extortion of attorney's fees and the 3 parading of an entity by the name of CAFI, which 4 had already filed over a hundred requests, from 5 filing -- from seeking fees that it was not 6 entitled to. 7 And the lawsuit obviously was not 8 just on behalf of Gulf Stream, but a putative 9 class action to stop it from happening statewide. 10 Q. Gulf Stream also filed State Court 11 counterclaims that we discussed against this, I'll 12 call it the same group, generally, of RICO 13 defendants; correct? 14 A. Right. 15 Q. And the motivation of Gulf Stream in 16 filing those State Court counterclaims, to your 17 knowledge, was it the same motivation as filing 18 the RICO lawsuit? 19 MR. GOLDSTEIN: Asked and answered. 20 THE WITNESS: The counterclaim had a 21 number of issues, including obtaining the 22 right to release the CAFI documents. But we 23 were also seeking -- as we said in court, we 24 recognize that you don't prevent someone from 25 filing a public records request. We wanted 147 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 to have the court regulate the timing and 2 manner in which the town had to respond to 3 that, based on the volume, which is what the 4 issue on appeals would be, whether or not the 5 court of equity could -- we had the McMillan 6 case which is over a hundred years old from 7 the Florida Supreme Court saying that one 8 person can't go in and close a clerk's office 9 and make it inaccessible to the rest of the 10 public, which is what was occurring here. 11 And then we had a case out of I think 12 the 1st District that affirmed the circuit 13 court judge who set like a year to respond 14 because there were 19 complex requests. Here 15 we had thousands. 16 So we wanted to see if the court 17 would actually help us administer processing 18 in some way through a commissioner or through 19 guidance so that we didn't just get sued 20 right and left because we weren't responding 21 quickly enough. 22 BY MR. DE SOUZA: 23 Q. That was State Court counterclaims. 24 A. Right. 25 Q. Are you aware of any other motivation 148 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 by Gulf Stream, other than what you've described, 2 in filing the RICO lawsuit? 3 A. The RICO lawsuit did seek to enjoin 4 the extortion and the fraud that was occurring, 5 the criminal conduct that was occurring. 6 Q. Enjoin it how, to your understanding? 7 A. I just thought one of the prayers of 8 relief was for an injunction, I would presume one 9 thing -- 10 MR. GOLDSTEIN: Objection -- 11 THE WITNESS: One form of injunction 12 would be for the court to direct that any 13 lawyers involved in this litigation -- the 14 statute only allows you to collect attorney's 15 fees. Here there were no contingency fee 16 agreements. 17 When you read Mr. O'Boyle's memo he 18 says there's going to be one law firm 19 handling this, it's my son, and they're going 20 to have contingency fees; i.e., get a 21 multiplier. 22 There are no contingency fee 23 agreements ever, according to Mr. Chandler. 24 The law firm is settling all the cases 25 themselves without talking to him. All the 149 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 money is going to the law firm. 2 So you would expect that a federal 3 judge, had the case been processed to an 4 injunction, would have said, you cannot make 5 demands for fees that weren't actually 6 incurred. And you can't demand contingency 7 fees if you don't have a contingency fee 8 agreement. And you can't demand five times 9 the fees that were actually expended under 10 any circumstances because there's no damages. 11 And you can't share the fees with the client, 12 which is what was occurring with Mr. Gray 13 when you look at the documents. 14 BY MR. DE SOUZA: 15 Q. With respect to the RICO lawsuit, did 16 Gulf Stream intend to seek relief in the form of 17 barring the defendants from filing public records 18 lawsuits? 19 A. In the RICO case? 20 Q. The RICO case. 21 MR. GOLDSTEIN: The document speaks 22 for itself. 23 THE WITNESS: That wasn't my 24 understanding. 25 BY MR. DE SOUZA: 150 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. I'm speaking beyond the complaint. 2 I'm speaking in terms of Gulf Stream's intentions 3 of what it hoped to get out of the RICO lawsuit. 4 A. No one ever expected any court or the 5 result of this litigation would be that somebody 6 wouldn't file a public records request. 7 Obviously, anyone has the right to file a public 8 records request. 9 I think the nuance in this RICO case 10 that is escaping us is that you can have 11 litigation, but when you have a pretend plaintiff 12 that is just the law firm going out and filing 13 requests in order to make it difficult or 14 impossible to comply, and the whole purpose of 15 that is to extort money that has not been earned, 16 under the threat that if you don't pay it you're 17 going to get more requests and more lawsuits... 18 Gulf Stream was the poster child for 19 the state, for the O'Boyle law firm and CAFI, to 20 tell people, we want $5,000, we want $10,000. We 21 spit out our form complaint, we served you with 22 it. Pay us five or $10,000 or you're going to 23 look like Gulf Stream. You only had five 24 requests. Now, Mr. Delray, don't give us a check, 25 see when you have 50 and then you'll have a 151 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 hundred. 2 So that was the scheme, that was the 3 scam. And we expected that the illegal parts 4 would be enjoined, not the filing of public 5 records requests. 6 MR. DE SOUZA: With that said, I'll 7 turn the floor over to anyone else that may 8 have questions. 9 MR. TACHER: No questions. 10 11 EXAMINATION BY 12 MR. COHEN: 13 Q. Good afternoon, Mr. Sweetapple. My 14 name is Jordan Cohen. I represent Richman Greer 15 law firm and Gerald Richman in connection with 16 this lawsuit. 17 I just have a couple of clarifying 18 questions. 19 A. Sure. 20 Q. You testified this morning on direct 21 that you were involved in preparation of the 22 statement of facts. Do you recall that testimony? 23 A. I remember that initially I was 24 drafting -- that's the first thing Gerry asked me 25 to do. 152 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Q. Okay. And I guess what I'm trying to 2 understand; was that some sort of separate 3 document or are you talking about the statement of 4 facts that ultimately made its way to the RICO 5 complaint? 6 A. I'm talking about a statement of 7 facts that would be used for a pleading, telling 8 the story of what occurred based on what I had 9 investigated. 10 Q. And is it your understanding that 11 that statement of facts was used as the basis for 12 the statement of facts in the RICO complaint which 13 you were -- 14 A. Partially, partially. 15 Q. Did you have an opportunity to review 16 the statement of facts in the RICO complaint 17 before it was filed? 18 A. I reviewed the entire complaint 19 before it was filed. 20 Q. And you believe that the factual 21 allegations in the RICO complaint were accurate, 22 correct? 23 A. I believe so. 24 Q. And you also believe that the legal 25 claims asserted were meritorious, correct? 153 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 A. I had discussed the legal theories 2 with Gerry and with Joanne. I had discussed them 3 with my partner. I had some research done by my 4 office. I was present at the meetings with the 5 various counsel. One time I think there were four 6 or five counsel discussing the theories and the 7 facts. 8 Q. And you continue to hold that belief 9 today, correct? 10 A. Absolutely. 11 I believe what you're going to see, 12 if I'm allowed to spout off, which my attorney 13 doesn't approve of; but I think what we're going 14 to see, unfortunately, an analog which we're 15 already starting to see in some of the cases, not 16 in the 11th and not in Florida, but we're seeing 17 it in the country, is that we are going to 18 recognize that either because there's too many 19 lawyers or because our ethics are eroding, that 20 lawyers and -- lawyers are going to be using the 21 courts to defraud and make money by fraud. And 22 we're going to see more and more cases -- you see 23 Medicare fraud, Medicaid fraud; it's a 24 multibillion dollar program. Doctors that are 25 pretending to treat people. And we're going to 154 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 see cases where more and more, the plaintiff 2 doesn't exist, the plaintiff is some entity the 3 lawyer created, it's a fiction. The accident 4 didn't occur. The injuries are all made up. The 5 doctors are making up the injuries. And right now 6 the law basically protects that. And as we're 7 confronted with more situations like this, I 8 expect to see the law change to meet the 9 circumstances. 10 Q. You also testified on direct 11 examination that the RICO complaint that was filed 12 was prepared by Eric Sodhi at the Richman Greer 13 firm? 14 A. He was one of the -- Gerry had a team 15 working -- Eric, from my conversations with him, 16 was a consummate expert on RICO. I know that 17 Gerry had tremendous expertise and lectured on it, 18 but Eric just seemed like he was very, very well 19 versed. 20 Q. And I know you testified on direct 21 and also in response to my questions that you had 22 some involvement in connection with the 23 preparation of the statement of facts. 24 To your knowledge, were there other 25 attorneys outside of the Richman Greer law firm 155 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 who were involved in the preparation of the RICO 2 complaint? 3 A. Yes. And Joanne knew about -- she 4 worked on the facts and edited what I did and 5 reviewed. She was involved in discussing the 6 theories, making sure that the town was acting 7 properly and making sure that the case was bona 8 fide. 9 And there were a team of lawyers 10 that -- we recognized that we were on the cutting 11 edge. This is not something that's been seen in 12 our state. 13 And the court, even the trial court 14 and the appellate court, recognized that we're in 15 sort of unchartered territory in terms of, how do 16 you deal with this. And judges say, well, the 17 Legislature is going to have to do something. 18 This is totally improper. But the law in the 11th 19 Circuit is, if it's done -- if the predicate act 20 is a lawsuit, it will not be a RICO. 21 Q. And -- I'm just about done. 22 I understand you're here in two 23 capacities. 24 When you say that we understood that 25 this was on the cutting edge, who are you 156 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 referring to? 2 A. I think all the lawyers. All the 3 lawyers realize we're dealing with a very, very 4 unprecedented and novel situation. And Gerry was 5 confident that the law in some of these other 6 circuits would be adopted by the 11th. And I 7 think he and I still believe that will occur. 8 Unfortunately, it's going to take more fraud and 9 litigation before this absolute rule is modified. 10 It's a slippery slope because, as 11 lawyers, if we file a lawsuit in good faith, we 12 want to be protected, we want people to have the 13 right to go to court and claim anything and the 14 court should be open and the right to public 15 access for documents, for public records, has to 16 be protected. Those are sacred rights. But the 17 problem is what happens when people start using 18 those rights as the prerequisites to -- as the 19 precursor to a fraudulent scheme. 20 Q. Asking in your capacity as the 21 corporate representative for the Town of Gulf 22 Stream, had that fact, the fact that this was 23 something that was on the cutting edge that the 24 legal team felt comfortable with, was that 25 something that had been communicated to the Town 157 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 of Gulf Stream prior to filing the RICO complaint? 2 A. I wasn't privy to Jerry's meetings 3 with the town or his conferences with Scott, but 4 Scott was present during meetings. 5 I guess I have to say yes, because he 6 was there when the lawyers were talking, he's a 7 lawyer, so it was communicated while he was 8 sitting at the table. 9 Q. When you're referring to Scott, 10 you're referring to Mr. Scott Morgan, the Mayor? 11 A. Yes. 12 I think he understood that there's no 13 precedent for this. This hasn't happened anywhere 14 in the country, but now we're seeing it's 15 happening elsewhere. 16 MR. COHEN: Those are all the 17 questions I have. Thank you. 18 MR. TACHER: No questions. 19 MR. DE SOUZA: I have no more 20 questions. 21 MR. HOCHMAN: No. 22 MR. DE SOUZA: We are done. 23 MR. HOCHMAN: The witness will read 24 his deposition for the town if it's ordered. 25 MR. TACHER: If it's ordered, I will 158 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 take a copy. 2 MR. HOCHMAN: Are you ordering this 3 deposition transcript? 4 MR. DE SOUZA: Not today. 5 MR. HOCHMAN: If it is ordered, my 6 office will take a copy and a condensed 7 version. 8 MR. COHEN: I will order a copy if 9 it's gets ordered. 10 MR. GOLDSTEIN: Me as well. And 11 he'll read on both. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 159 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 (The deposition concluded at 1:05 p.m.) 2 3 4 CERTIFICATE OF OATH 5 6 STATE OF FLORIDA ) 7 COUNTY OF BROWARD ) 8 I, Doreen Fox Krenchicki, Certified Court 9 Reporter, Registered Professional Reporter, Certificate of Merit Reporter, Certified Realtime 10 Reporter, Notary Public, State of Florida, certify that ROBERT SWEETAPPLE personally appeared before 11 me on the 30th day of November 2016 and was duly sworn. 12 Signed this 30th day of January 2017. 13 14 15 __________________________________ DOREEN KRENCHICKI, 16 Certified Court Reporter Registered Professional Reporter 17 Certificate of Merit Reporter Certified Realtime Reporter 18 Notary Public, State of Florida 19 20 21 22 23 24 25 160 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 DEPOSITION ERRATA SHEET 2 Page No. Line No. Change to: 3 4 Reason for change: 5 Page No. Line No. Change to: 6 7 Reason for change: 8 Page No. Line No. Change to: 9 10 Reason for change: 11 Page No. Line No. Change to: 12 13 Reason for change: 14 Page No. Line No. Change to: 15 16 Reason for change: 17 Page No. Line No. Change to: 18 19 Reason for change: 20 Page No. Line No. Change to: 21 22 Reason for change: 23 SIGNATURE: DATE: 24 Please forward the original signed errata sheet to this office so that copies may be distributed to 25 all parties. 161 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 CERTIFICATE OF REPORTER 2 3 STATE OF FLORIDA ) 4 COUNTY OF BROWARD ) 5 6 I, Doreen Krenchicki, Certified Court 7 Reporter, Registered Professional Reporter, 8 Certificate of Merit Reporter and Certified 9 Realtime Reporter, do hereby certify that I was 10 authorized to and did stenographically report the 11 deposition of ROBERT SWEETAPPLE; that a review of 12 the transcript was requested; and that the 13 foregoing transcript, pages 6 through 158, is a 14 true record of my stenographic notes. 15 I further certify that I am not a relative, 16 employee, attorney or counsel of any of the 17 parties, nor am I a relative or employee of any of 18 the parties' attorney or counsel connected with 19 the action, nor am I financially interested in the 20 action. 21 Dated this 30th of January 2017. 22 23 24 DOREEN KRENCHICKI, CCR, RPR, CRR, CM 25 162 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF FLORIDA 2 CASE NO.: 9:16-cv-81371-BB 3 DENISE DE MARTINI, 4 Plaintiff, 5 v. 6 TOWN OF GULF STREAM, et al, 7 Defendants. ----------------------------- 8 IN RE: DEPOSITION OF ROBERT SWEETAPPLE TAKEN: 11/30/16 9 DATE SENT TO WITNESS: JANUARY 30, 2017 10 TO: ROBERT SWEETAPPLE c/o Sweetapple, Broeker & Varkas, P.L. 11 20 SE 3rd St Boca Raton, FL 33432-4914 12 The reference transcript has been completed 13 and awaits reading and signing. Please arrange to stop by our office at 101 14 NE Third Avenue, Suite 1500, Ft. Lauderdale, Florida to read and sign the transcript. Office 15 hours are from 9 a.m. - 4 p.m., Monday through Friday. The transcript is 158 pages long, and you 16 should allow yourself sufficient time. It is suggested that the review of this 17 transcript be completed within 30 days of your receipt of this letter, as considered reasonable 18 under Federal Rules; however, there is no Florida Statute to this regard. 19 The original of this deposition has been forwarded to the ordering party and your errata, 20 once received, will be forwarded to all ordering parties as listed below. 21 Thank you, 22 Doreen Fox Krenchicki, CCR, CM, RPR, CRR 23 Daughters Reporting, Inc. 954-755-6401 24 cc: Joshua Goldstein, Esq. cc: Robert Tacher, Esq. 25 cc: Jordan S. Cohen, Esq. Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 1 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 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42:12,13,22 B B 4:9 5:1 6:1 back 11:23 13:17 15:18 16:6,25 19:18 20:13,18 21:2 21:19 29:5 50:19 51:19 75:7 76:25 93:23 115:9 117:10 128:3 130:9,11 bankruptcy 54:23 55:5,11 55:22 bar 28:10 78:2,4 78:6 79:4,9,11 79:16 80:4,5 80:18,24 92:17 97:9 102:2,5 103:20 109:5,5 114:3,4 barrage 15:3,7 103:11 barraging 99:23 barred 114:16 barring 149:17 based 9:5 17:14 36:16 55:14 66:2,22 68:21 72:16 85:8 86:16 100:6 106:18 116:20 129:25 140:2 143:11 147:3 152:8 basically 13:3 20:2 43:16 45:23 64:17 100:4 106:23 107:8 110:4 116:17 154:6 basing 140:20 140:24 141:3,7 141:14 basis 57:5 126:4 152:11 Beach 3:17 72:22 89:23 bear 140:18 beat 48:3 becoming 55:13 began 15:8 16:3 begun 53:1 behalf 2:8,15,22 3:10,18 8:24 10:10 12:6 13:10 17:22 22:17 80:11 87:5 119:5 128:7 134:3 3 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 146:8 behave 119:12 behest 99:4 belief 57:2 99:19 153:8 believe 9:13,18 9:23 10:3,8,9 15:7,20 16:11 17:25 21:12,17 22:3 27:24,25 30:3,8,20 33:10,23 34:9 35:18 37:1,10 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Broeker 4:22 73:11,17 162:10 brought 11:7 12:8 16:12 17:22 53:11 100:20,21 101:6 102:14 114:1 BROWARD 159:7 161:4 BURKE 2:12 bus 72:18 C c/o 162:10 CAFI 13:10 17:23 19:16 20:24 22:5 28:5 42:5,18 42:20,24 43:11 43:13,16 44:3 44:10,17 52:5 52:8,12 59:8 65:19 66:12 71:17,18 91:1 92:23 102:14 102:17,20,21 102:25 103:1 103:25 109:14 109:15 111:10 112:10,18 119:20 123:6 128:7 130:25 131:10,11 132:16 134:5 141:8,19 143:8 143:14,21 146:3,22 150:19 California 69:6 69:16 call 46:20 108:1 108:19 110:14 146:12 called 42:21 48:24 49:1 58:14 91:7 94:10 101:3,15 103:14 calling 91:17 94:20,21 calls 92:21,22 125:13 candy 142:3 cap 106:9 capable 43:12 capacities 155:23 capacity 6:24 10:14 128:10 156:20 capstone 13:21 caption 25:10,25 93:25 137:8 card 71:16 cards 82:3 care 66:19 case 1:2 6:18,21 16:23 17:7 18:5 22:17 25:10,25 34:14 36:21 38:21 39:5,20 44:8 48:25 53:10,24 55:11 58:19 63:2 64:20 65:3,5,6,11,22 68:5 84:4 86:11,24 95:15 100:19 102:14 108:22 109:10 115:17 116:9 117:3,3,19 119:7,9,25 120:21 125:6 126:15,16 128:12,20,22 130:11 131:3 131:23 132:2 133:5,9,16 134:5,9 138:6 141:9 147:6,11 149:3,19,20 150:9 155:7 162:2 cases 17:22 18:15 38:17 39:5 69:8 74:17 78:23 79:11 80:13 85:4,4 92:9 128:15,16 132:9 133:19 133:25 134:22 135:22 136:18 148:24 153:15 153:22 154:1 categorically 52:11 categories 24:23 24:25 39:13 cause 1:24 cc 162:24,24,25 CCR 161:24 162:22 Center 3:7 91:12 91:15,25 92:4 certain 6:25 10:19 11:24 17:12 24:23,25 32:12 36:15 59:4 99:11 125:25 126:8 126:19 128:24 certainly 7:15 55:17 66:22 71:19 72:6 94:4 119:12 Certificate 1:21 159:4,9,17 161:1,8 certified 1:20,21 103:20 159:8,9 159:16,17 161:6,8 certify 159:10 161:9,15 chair 24:5 102:4 chaired 102:5 4 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. chance 76:3 Chandler 9:21 10:17 13:4,5 19:15 20:11 22:9,16 28:5,6 29:8,9 40:7,13 40:14 41:5,9 44:23 45:4,5 45:22 46:4,11 46:13 47:2,5 47:18,22 48:14 48:17,21 49:6 49:23 50:16 51:9 52:15,23 53:6,20,22 54:4,18,21,25 55:4,9,10,16 56:3,11,24 57:8,18,21 58:7,13 62:19 66:23 69:25 70:2,9 71:8,11 71:20 72:7 74:19 94:3,17 95:2,22 103:14 104:8,17,19,22 105:2 106:24 109:14 110:8 111:18 113:5 129:10,17,23 130:7,16 139:2 139:16 140:22 141:4,17 148:23 Chandler's 21:3 51:19 52:13 55:5,7 70:8 71:4 75:10,17 79:5 129:19 130:2 141:1 change 55:6 122:6 154:8 160:2,4,5,7,8 160:10,11,13 160:14,16,17 160:19,20,22 changing 69:7 69:15 charities 45:25 67:20 check 101:2 150:24 chicken 105:1 child 150:18 children's 67:2,3 Chris 76:14 85:12 Christopher 99:5 126:2,20 129:11,18 chronology 10:16,20 13:3 20:18,21,21,22 21:6 28:8 51:22 103:18 104:4 107:7 109:9 church 72:4 circuit 115:22 147:12 155:19 circuits 156:6 circumstances 149:10 154:9 circumventing 70:13 cited 116:10 Citizens 42:11 42:13,22 city 107:18 civil 53:24 54:12 55:25 56:12,18 60:1 61:5 103:21 107:11 107:11,12 130:10 claim 29:22 37:21 39:21 60:1 61:18 111:3 113:20 116:24 117:1 118:14,16 156:13 claims 31:22 61:6,14 62:15 64:15 95:13 116:19 117:6 118:13 121:6 138:3 152:25 clarifying 151:17 class 136:24 137:4 146:9 classic 115:2 clean 24:1 clear 26:22 56:4 84:22 86:10 clearly 130:2 clerk 15:21 16:12 clerk's 147:8 clerks 136:7 client 13:11 17:5 17:13 27:2,7 34:6 36:17 42:2 46:10 51:17 65:1,25 66:3,5 85:25 86:19 108:16 108:17 114:22 118:5 119:11 119:12 123:1,2 149:11 client's 42:2 134:18 clients 62:16 122:5 136:5 clients'66:4,18 cliff 13:4 close 66:7 141:25 147:8 closing 99:24 Clough 92:12 CM 161:24 162:22 co-counsel 27:8 122:5 Coastal 92:14 coerce 99:21 Cohen 3:4 4:6 144:9 151:12 151:14 157:16 158:8 162:25 cohorts 56:17 coincidence 103:12,19 111:25 coincidentally 102:12 107:10 COLE 3:15 collect 148:14 come 53:21 54:9 59:19 60:20 75:15 81:17 82:11 136:8,18 comes 88:22 105:4 114:13 comfortable 116:15 156:24 coming 102:18 112:15 comments 145:8 145:10 Commerce 102:18,20 128:8 commission 14:18 97:25 commissioner 123:24 147:18 commit 56:25 57:9 committed 41:15 43:15 44:11,19 57:19 57:22 62:10 63:10,14,17 64:2,8 68:11 92:1 94:2,11 96:2,9,20 97:3 120:9 121:24 124:9,14,19 committee 102:5 committees 102:6 committing 43:1 43:21 communicable 39:16 communicate 93:7 communicated 26:19 47:2 58:7 86:18,22 87:7 89:25 90:5,23 93:10 106:13 120:5 123:10 156:25 157:7 communicating 21:1 27:6,9 89:6 92:25 communication 34:7 46:15 49:4 77:16 88:24 125:17 134:4 communications 17:15 25:10 32:15 33:1,13 33:16 42:25 53:19 72:10 81:2,4 85:21 87:19 90:10 93:14,17,19 94:4 113:4 118:5,19 129:23 130:6 130:17 companies 67:21 69:11 112:8 company 79:1 102:14 compared 13:6,7 51:19,22 competence 39:18 complaint 4:20 9:11 32:17 33:3 34:4 36:21,24,25 37:7,11,18,20 38:5 64:16,24 79:10 80:21,23 96:14,15 112:25 129:1,2 5 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 129:5 131:2 136:24 137:4,8 150:1,21 152:5 152:12,16,18 152:21 154:11 155:2 157:1 complaints 29:13 80:10 101:18 131:15 132:10,24 135:20 complete 20:17 30:16,18,21 67:8 68:24 completed 162:12,17 completeness 23:13 complex 147:14 comply 150:14 compound 126:4 computer 18:11 18:14 computers 68:4 con 69:19 concept 32:3 39:8,9 111:2 concern 54:20 139:14 141:18 143:4,7 concerned 10:20 19:1 55:17 70:17 83:8 143:5 concerning 9:12 29:21 32:16 33:2 86:5 90:24 91:1 93:14,17 139:2 concerns 27:16 55:14 concert 15:10 85:7 conclude 72:3 concluded 32:4 43:18 68:23 142:22,23 159:1 conclusion 9:5 69:24 94:13 118:24 126:12 conclusions 66:3 138:18 condensed 158:6 conduct 68:5,18 70:7,8,18 71:5 72:2 78:3,7 94:22 95:1 111:21 114:5 148:5 conducted 68:22 conference 59:22 60:2,6 60:17,17,19 63:21,24 64:1 72:23 75:1,5 75:16,20 82:25 83:1,18 84:13 85:9 86:9 117:13 conferences 60:25 72:25 74:2 157:3 confidence 108:20 confident 156:5 confidential 27:13 59:22 76:20 77:4,11 77:13,20 85:23 131:10 confirm 37:3 48:4 65:2 confirming 97:16 confirms 98:11 confronted 67:23 105:8 154:7 congratulate 39:2 conjunction 143:17,19 144:18 connected 161:18 connection 6:17 21:14 50:25 58:10 151:15 154:22 consider 29:3 51:9 122:14 123:1,12 124:4 considerably 130:24 considered 43:11 48:10 162:17 consolidated 136:2 constituted 111:21 consult 99:1 100:21 102:1 103:16 104:17 104:21 105:20 106:23 consultations 107:20 consulted 125:11 consulting 101:8 101:9 102:24 104:3,24 105:3 108:6 consummate 154:16 contact 82:10 contacted 13:5 46:8,11 104:22 contemplated 99:14 126:23 context 18:5 96:11 contingency 148:15,20,22 149:6,7 continue 46:9 85:21 153:8 Continued 3:1 5:1 contracted 70:16 contractors 45:8 contradicted 9:11 52:16 contrary 52:12 control 25:14 28:19 33:6 68:6 conversation 12:14 41:4 54:22 55:2,8 55:12 77:20 82:2 88:4,23 90:8 91:24 94:19 130:12 conversations 28:24 54:10 56:1 59:19 60:21 61:4,10 61:22 78:19 80:2 83:4,15 91:24 102:13 124:5 139:7 154:15 conveyed 107:25 cooperate 77:24 copied 21:8 33:7 copies 16:12 160:24 copy 4:14,17,23 5:4 8:7 18:18 23:6,9,14,18 30:13 33:11,17 34:10 36:10 37:2 87:4 88:8 88:13 120:16 120:19 141:17 158:1,6,8 copying 25:15 core 43:6 67:11 corporate 4:13 7:11 8:3,13 28:4 141:8 156:21 corporation 42:16,23 80:15 correct 8:25 10:11 17:7 21:9 27:3,4 35:3,4 37:22 38:5 41:6 43:21,22 44:25 49:23 57:16 60:10 73:18 76:20 86:15,19 88:18 89:23 104:8,15 136:22 138:19 138:20 146:13 152:22,25 153:9 corrected 50:19 118:7 corroborate 52:25 53:2 corruption 67:10,16,16 68:11,11 corrupts 69:4 cost 105:20 costs 101:25 council 95:11 97:20 councilwoman 123:22 counsel 5:10 16:18 17:12 26:2 28:2,21 28:25 30:2 32:18 34:14 35:22 42:3 47:13 58:19 59:12 64:18 74:1 81:6,8 98:25 100:15 118:20 119:4 125:6 131:9,13 133:24 134:1,5 153:5,6 161:16 161:18 count 38:4 65:8 counter-defen... 131:5 132:12 6 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. counterclaim 108:23 135:17 135:24 136:3 136:15,20 146:20 counterclaims 131:14 132:9 132:24 135:20 136:9 145:18 146:11,16 147:23 country 153:17 157:14 County 38:22 71:25 102:6 159:7 161:4 couple 50:2,10 50:12 61:22 63:25 122:17 151:17 course 26:5 43:18 134:14 court 1:1,20 21:23 25:8 29:12 49:18 50:4,8 51:2 65:2 75:6 80:6 80:19 93:25 94:15 95:6,25 108:15 109:19 109:20 114:1 114:11,13,21 115:1,21 117:6 117:7 120:1 131:3 132:3 134:8,13,15 140:25 145:18 146:10,16,23 147:1,5,7,13 147:16,23 148:12 150:4 155:13,13,14 156:13,14 159:8,16 161:6 162:1 courthouse 38:22 75:9,10 75:15 83:16 courts 69:17,17 69:22 108:21 153:21 cover 70:6 129:19 130:3 covered 141:13 covers 7:22 COY 3:6 crash 114:20 crazy 112:8 create 67:4,21 67:22 133:12 created 154:3 credibility 119:19 credible 51:9,15 credit 71:16 crime 43:3,21 44:11,19 57:19 62:10 92:1 94:2,11 96:2 120:10,10 121:24 124:9 124:14 crimes 43:1 81:12 criminal 32:5 39:15 40:5 41:14 43:15 44:1,2,3,4 62:13,20 63:7 63:15 64:22 71:23 72:3 94:10,14,18,22 95:1,4 107:12 107:13 112:6 114:5 123:8 148:5 criminals 44:11 criticize 67:13 cross 122:21 CRR 161:24 162:22 custody 25:14 28:18 33:6 cut 12:23 cutting 155:10 155:25 156:23 Cynthia 26:12 D D 4:1 Daddy 65:13 Dade 38:22 71:25 102:6 damages 149:10 Dan 6:8 65:12 dangerous 68:13 DANIEL 2:4 date 25:15 46:10 46:21 60:7 73:5,5,13 74:9 81:19 160:23 162:9 dated 4:23 37:1 50:14 88:9,17 161:21 dating 16:6 daughter 83:8 112:3 Daughters 162:23 Dave 89:18 90:5 90:10 day 24:7 34:23 72:4 74:10 99:25,25 132:1 159:11,12 days 135:8 162:17 de 1:4 2:4,5 4:5 6:6 8:9 13:23 23:5,13,25 25:19,21 30:12 31:2,12,19 34:18,24 35:1 36:18,19 37:4 37:9,25 38:2 41:1 44:6,15 44:22 47:25 48:3,15,20 56:23 57:13 58:5,17 61:7 62:7,17,22 63:3,16 64:6 64:11 71:3 72:19 73:14 76:5,8,11 78:10 87:22 88:6,11 95:16 96:6,25 97:12 98:15 103:9 105:22 107:22 112:22 118:1 118:10,21 119:1 120:14 120:19,22 121:14,19,20 122:1,8 124:21 125:4,20 126:17,25 127:9 128:22 128:23 129:7 132:7,22 134:24 137:17 138:25 140:4 142:9 144:3,12 144:16 147:22 149:14,25 151:6 157:19 157:22 158:4 162:3 dead 48:3 114:21 deal 80:5,18 86:11 101:6,10 155:16 dealing 82:6 90:21 104:5 156:3 dealings 19:14 55:20 dealt 19:17 debating 61:16 61:25 80:7 debrief 13:6 debriefed 41:11 110:25 debriefing 113:5 dec 108:14 decide 135:9 decided 50:8 52:1 72:16 115:7 135:11 135:14 136:14 136:16 decision 132:5 139:21,25 declaratory 131:7 134:9 decree 109:19,20 deemed 39:12 defamatory 39:12 defend 46:9 99:11 100:22 119:9 defendant 2:15 2:22 3:18 4:14 4:17 5:4,6 6:19 6:25 7:19 9:16 9:22 23:7,10 23:15,19 32:21 120:17,20 124:22 125:1 129:12 131:5 137:15,22 139:11,18,22 140:1,6 142:13 defendants 1:10 3:10 38:15 63:5,7,10 64:2 64:8 86:23 87:9 95:14 96:1,9,20 97:3 110:9 111:4 136:23 137:7 138:3,19,24 139:3,17 146:13 149:17 162:7 Defender's 71:24 defending 100:11 101:8 102:14 defense 117:4 7 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 125:25 126:7 126:19 defenses 108:12 118:13 121:7 defer 119:9,23 define 42:11 defined 41:22 43:1,7 95:18 definitely 143:25 defraud 69:18 94:7 109:1 112:7 115:3 142:17 153:21 defrauding 114:8 dehydrated 144:1 Delray 150:24 delving 124:5 demand 149:6,8 demanding 114:7 demands 149:5 DeMartini 6:18 10:21 17:6 19:2,5,17,21 20:1,11,23 35:13 36:1,4,6 37:20 39:20,25 44:1 48:13 49:7 64:22 65:5,20 66:6 66:16 68:20 94:2,6,14 95:7 119:17 120:9 120:12,13 121:24 124:9 124:13,17,18 127:23 128:6,7 128:14 130:20 131:4,11,15 132:11,25 133:18 135:2 139:22 140:5 140:14 142:12 142:20 143:2 143:14,19 144:18,22 145:1 DeMartini's 21:15 26:6,20 41:4 66:21 70:23 95:20 127:12,17 demonstrated 72:16 demonstrates 71:7 denied 52:11 100:8 129:13 Denise 1:4 6:18 17:5 19:1,20 44:1 66:21 119:17 120:9 120:12,13 121:24 127:12 127:17,22 128:6,6,13 131:4 132:11 139:22 142:12 162:3 deny 129:15 depending 34:22 depos 24:7 deposed 14:5,13 53:10 deposit 105:20 deposition 1:17 1:24 4:12 7:1,4 7:11,21,22 8:3 8:12,18 11:16 14:1,12,19 18:24 49:3 52:2 53:12 55:10 58:10,18 82:20 117:19 117:21 119:3,5 157:24 158:3 159:1 160:1 161:11 162:8 162:19 describe 98:5 described 148:1 describes 45:19 describing 72:2 DESCRIPTION 4:11 5:3 designate 7:14 designated 7:15 7:25 8:20,23 designating 7:17 designee 6:25 10:15 142:19 143:1 desire 54:16 119:14 desiring 15:5 desperately 134:12 136:10 destroy 68:1,6 destroying 70:12 detail 112:21 detailed 110:15 details 107:21 determine 135:16 determining 138:2 dialogue 77:11 different 22:13 31:24 34:1 38:14 61:17 104:6 112:8 122:17 136:5,7 136:9 137:7 difficult 119:11 150:13 direct 129:23 148:12 151:20 154:10,20 directed 132:16 direction 140:16 director 131:1 dirty 109:16 disclose 59:21 disclosed 59:25 60:24 61:4 disclosing 64:19 disclosures 5:5 120:18,21,24 121:4 123:23 discounted 97:17 98:13 discover 79:22 discovery 25:8 119:14 120:3 discuss 8:1 12:2 12:13,25 13:16 14:7 74:15,22 77:4 86:7 119:8 discussed 12:5 54:11 61:23 75:14 78:15 79:9,17 86:12 87:16 90:15 96:12 107:7 113:16 116:6 125:18 146:11 153:1,2 discussing 11:20 12:20 26:16 49:7 76:24 79:10 153:6 155:5 discussion 13:14 40:16 81:10 85:25 86:4 112:3 113:25 139:4,8 142:6 144:14 145:4 145:17 discussions 55:6 111:12,17,20 118:18 139:1 disease 39:16 dismiss 135:15 dismissed 53:11 65:3 dispute 40:9 disqualify 78:14 78:17 disseminated 26:4 distributed 160:24 District 1:1,1 135:16 147:12 162:1,1 divisions 136:18 doctors 153:24 154:5 document 8:15 18:10,18 19:11 21:15 24:13 25:17 26:4 28:19 29:2 35:21 38:9 76:18 85:16,19 85:20 121:17 125:5,8 149:21 152:3 documentation 130:23 documents 8:19 10:19 11:5 13:8,19 14:21 17:4,7,12,16 17:18,21,24,25 18:6,14,20 19:4,7,17 20:2 20:9 21:6,13 21:19,20,22 22:5,9,12,15 24:24,25 25:8 25:9,13,23,23 26:10,10 27:15 27:20,23 28:1 28:6,18 32:22 32:25 35:23 48:5 51:20,25 68:21 107:6 108:13,21,23 110:4 121:12 123:6 131:9 133:11 134:11 136:20 141:4,8 141:12 146:22 149:13 156:15 doing 6:9 24:21 39:25 43:12 46:6 64:20 67:24 70:9 72:4 75:23 80:11 85:6,6 8 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 102:9 109:16 111:10 114:15 115:20 116:15 126:24 dollar 153:24 dolphin 82:3 Donna 123:22 doozy 76:9 Doreen 1:19 159:8,15 161:6 161:24 162:22 doubt 134:20 142:14,24 doubts 114:24 dozens 71:13,13 103:6 134:2,2 draft 29:6 96:14 drafted 50:15 drafting 95:12 110:21 112:23 113:1,10 128:24 129:1 151:24 drafts 26:5 29:9 29:13 dressed 101:23 drop 82:1 Dropbox 20:22 21:7 22:2,6,19 22:20,22,24 28:7 107:4 141:5 duly 6:2 159:11 duty 135:7 E E 2:13 4:1,9 5:1 6:1,1,1,1 126:1 e-mail 4:23 24:20 46:16,18 48:14 51:21,21 87:23 88:4,9 88:13,15,20 89:12 108:4 117:14 143:16 e-mailed 47:9 50:18,20 120:25 e-mailing 48:21 e-mails 19:18,19 20:20 21:4 47:5,12,17,17 47:22 48:9,17 52:14 56:6,9 65:14 66:22 89:5 116:23 117:2,10 140:18 143:11 earful 102:25 earlier 16:7 72:25 80:2 81:1,3 85:10 95:18 early 46:21 52:19 72:10 79:21,24 111:6 111:12 112:3 earned 67:6 94:8 150:15 earnings 130:23 easier 22:1 24:8 East 3:8 eat 143:25 edge 155:11,25 156:23 edited 155:4 editor 93:11 129:21 editorialize 37:19 effect 139:20 effort 47:16 133:17 139:16 efforts 25:22 135:4 egg 105:1 eight 129:8 132:19 135:25 either 17:22 41:5 48:22 72:15 75:8 95:21 99:4 153:18 elected 134:8 elements 61:18 embarrassing 51:16 employee 161:16 161:17 ended 11:3 enforcement 32:15 33:1,12 41:13 87:8 engaged 15:22 55:21 engagement 97:14 98:4,17 98:20,24 127:2 127:11 engages 67:9 enjoin 148:3,6 enjoined 151:4 enjoy 39:10 enrich 109:16 ensued 15:6 entails 42:6 entered 40:19 77:17 entering 100:14 enterprise 43:16 59:8 111:15 112:6 130:21 134:23 142:21 144:23 entire 30:13 141:19 152:18 entities 15:4,23 36:4 44:17 59:6 103:5 121:10,22 entitled 36:12 80:8 146:6 entitlement 80:20 entity 36:6 42:6 42:10,12,17,19 43:11 59:9 68:7 80:21,22 103:7,9,9 128:7 131:12 146:3 154:2 entry 73:8,25 equity 147:5 Eric 117:11,14 129:6 154:12 154:15,18 eroding 153:19 errata 160:1,24 162:19 escaping 150:10 Esq 2:4,10,18 3:4,14 162:24 162:24,25 essentially 20:21 et 6:19 162:6 ethically 109:19 ethics 153:19 evening 19:23 everybody 112:11 evidence 52:13 94:5 109:11,17 119:15,18 123:8 131:25 132:4,17 134:13,21 exactly 22:6 23:3 54:14 61:23 103:15 examination 4:5 4:6 6:5 151:11 154:11 EXAMINED 6:3 example 44:9 exception 29:11 exchanged 47:5 exclude 63:23,25 122:9 excludes 43:7 excluding 26:24 27:1,10 29:2 41:24,25 60:12 61:8 exclusively 32:6 exhibit 8:2,11 23:6,9,14,18 24:10,23 32:9 32:11 37:5,6 40:21 73:10,16 88:8,13 120:15 120:15,16,19 124:22,25 125:5 137:3 Exhibits 5:10 exist 28:24 34:19 69:9 154:2 existed 16:23 61:18 101:18 103:6 existence 12:4 existing 18:20 exists 18:19 expand 99:7 101:12,13 104:23 107:19 expanded 100:8 101:14 104:11 108:9 expect 149:2 154:8 expected 150:4 151:3 expended 149:9 experience 39:7 45:16 71:22 137:24 expert 104:17,21 105:4,21 107:10,11 108:6 114:24 116:14 154:16 expertise 45:24 104:23 154:17 explain 130:4 explained 13:7 expressed 139:14 extensive 45:16 extensively 102:3 extent 28:3 48:9 118:4,18 122:4 125:15 134:18 extort 94:7 116:1 142:17 9 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 150:15 extorting 114:7 143:9 extortion 41:19 43:2 57:23 58:2 61:9,15 97:4 115:4 146:1,2 148:4 extracting 45:8 45:24 extracts 46:6 extremely 119:17 extricate 62:3 72:9,12 extricated 139:10 F F 1:8 3:12 faced 134:10 fact 13:9 40:4 57:9 65:21 66:10 78:15 85:1,2 94:5 96:13 99:13 108:13 113:25 156:22,22 facts 9:9 29:6 55:19 91:4 94:12 106:25 108:11 110:4,8 110:16,18,19 110:19 112:24 120:12 128:25 131:1 151:22 152:4,7,11,12 152:16 153:7 154:23 155:4 factual 57:5 152:20 fair 51:6 100:10 faith 21:17 138:4 156:11 fake 114:19,20 fall 15:7 16:2,7 familiar 19:9 44:24 45:1 81:23 82:13 102:7 far 57:14 70:7 77:21 84:7 85:18 111:4 127:15 138:17 139:15 140:18 145:22 fast-moving 61:24 favor 31:13 32:9 fax 99:25 February 15:20 16:10 92:18 105:12 federal 41:17 85:4 114:22,25 115:21 117:7 149:2 162:18 fee 148:15,22 149:7 feeling 75:25 fees 45:12,21 67:6,22 80:8 80:20,22 94:7 101:3,5 114:7 114:8 143:9 146:2,5 148:15 148:20 149:5,7 149:9,11 felony 39:15 felt 156:24 fiasco 90:22 fiction 154:3 fide 57:5 64:14 79:13,15 101:17 155:8 fiduciary 124:4 file 7:20 34:12 50:4,5 64:15 86:11 108:14 108:23 114:11 114:22 136:8 150:6,7 156:11 filed 1:24 13:10 16:7 22:17 51:2,3,12 65:3 78:13,16,22 79:12,21,25 80:9,14,21 99:3,12,15 101:18 105:13 108:13 125:19 126:1,8,20 129:5 131:14 131:23 132:10 135:5,24 137:4 137:23 146:4 146:10 152:17 152:19 154:11 files 10:25 11:6 11:12,14,24 18:14,25 19:7 26:15 71:6 filing 27:17 51:1 51:6 53:24 79:23 82:6 114:6 130:10 134:2 135:2,8 145:1,6,19,23 145:24 146:5 146:16,17,25 148:2 149:17 150:12 151:4 157:1 filings 25:8 28:4 29:12 125:19 fin 82:3 final 109:24 133:8 finalized 24:18 Finally 10:4 financial 119:21 financially 161:19 find 75:21 84:23 99:18 139:17 finding 26:8 51:16 100:23 finish 34:22 firm 2:5,11,19 3:5,15 26:24 41:25 73:3,8 73:17 78:14,22 78:25 79:7,14 79:22 80:11 95:14 97:13,21 98:4 100:3 101:16,17 102:3,19 105:9 105:10,14 109:17 112:10 113:13,18 119:19 126:6 130:25 131:22 133:23,24 135:2 137:13 137:20,24,25 138:15,18 140:2 142:11 143:8,17,20 144:19 148:18 148:24 149:1 150:12,19 151:15 154:13 154:25 firm's 98:23 127:16 first 4:15,18,20 5:7 15:3 23:8 23:11,16,20 36:25 37:7 38:20 39:4 46:8,12,24 47:2 54:2 55:23 71:23 75:13 79:22 81:5 84:21 88:19 101:14 105:7 106:4 110:5 111:5,7 119:8 124:23 125:2,7 151:24 fit 72:9 five 10:11,15 11:2,20 12:15 53:8 67:7 106:8 149:8 150:22,23 153:6 FL 2:7,14,21 3:9 3:17 162:11 flags 66:14 flip 29:16 floor 151:7 Florida 1:1,13 1:23 6:15 28:10 42:15,23 46:1 59:2 69:15 78:2,4,6 78:24 79:7 91:12,15,25 92:4,17 101:19 102:2 103:20 115:8 147:7 153:16 159:6 159:10,18 161:3 162:1,14 162:18 flow 76:7 flushed 52:18 focus 19:8 25:2 focused 12:15 19:20 21:5 128:11 follow 34:21 89:16 followed 32:19 136:13 FOLLOWS 6:3 FORD 3:6 foregoing 161:13 forgive 24:4 form 44:2,12,20 50:9 56:20,21 57:12,24 62:11 62:21,25 63:12 64:4,9,10,12 67:4 71:9 78:7 87:10 95:9 96:3,22 97:5 98:8 111:23 131:16,19 132:13 133:21 138:21 143:23 148:11 149:16 150:21 10 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. formal 140:25 formed 59:8 66:17,20 79:12 103:5,8 105:11 129:24 former 102:2 formerly 58:19 forms 109:7 forth 29:5 117:10 forward 160:24 forwarded 47:7 162:19,20 Foster 42:4 72:21,24 74:6 78:12 131:22 found 28:23 64:23 Foundation 42:12,13,22 four 11:2 20:16 67:6 80:13 105:13 115:11 153:5 Fox 1:19 159:8 162:22 foyer 84:14 frankly 18:2 89:2 90:17 121:1 fraud 43:15 69:21,23 115:4 134:19 148:4 153:21,23,23 156:8 fraudulent 68:10 94:18,22 111:14 114:5 123:8 156:19 Friday 162:15 friend 89:14 Ft 1:13 2:7,14,21 3:9 162:14 function 108:10 fundamental 71:7 funding 65:15 further 103:16 106:17 108:7 161:15 G gambit 27:13 Ganger 123:18 123:20 gather 25:22 gathered 25:23 83:23 general 12:12 38:19 43:14,15 63:25 86:18,22 General's 33:13 33:18,19,25 34:8 35:2,20 generally 10:25 39:13,19 68:17 83:14 120:10 146:12 generated 31:16 Gerald 1:8 3:12 88:16 103:22 104:14,20 112:2 151:15 Gerry 101:25 110:6 113:17 113:25 116:14 117:5,14 145:14 151:24 153:2 154:14 154:17 156:4 getting 88:1 101:5 102:22 112:9 144:1 give 14:25 20:24 22:4 38:10 68:3 69:1 73:4 107:3,6 108:15 108:16,16 113:11 150:24 given 105:23 go 11:12 15:18 19:10 20:13 21:2 23:5 26:8 35:24 37:4 40:2 64:20 71:12 72:11 88:6 93:23 99:8 114:25 115:24 128:3 133:3 144:12 147:8 156:13 goal 61:1 goes 74:1 121:9 going 11:7 14:9 17:1 22:1 23:5 23:14 32:5 37:19 55:18 59:21 60:16 64:19,20 67:18 67:24 70:12,12 70:15,18,24 72:3 76:9,21 77:4 82:13 85:20,24 86:7 99:15,16,17,18 100:4,18,23 103:4 104:1 109:21 110:21 111:2,8,9 112:16 115:24 115:25 117:10 117:24 119:12 119:23 120:14 122:6 123:15 124:21 132:17 133:3,7,10,15 134:10 137:2,9 141:23 143:24 144:2 148:18 148:19 149:1 150:12,17,22 153:11,13,17 153:20,22,25 155:17 156:8 Goldstein 3:14 8:8 25:17 26:11 30:7,20 31:12,18 34:16 34:21 36:14 37:24 43:23 44:12,20 47:23 48:1,7,18 56:20 57:12,24 58:8 60:22 61:12 62:11,21 62:25 63:12 64:4,10 70:22 71:9 76:2,6 78:8 87:10 95:9 96:3,22 97:5 98:8 105:17 106:20 111:23 117:24 118:3,17 121:12,16,25 125:15 126:10 126:22 127:8 128:20 129:3 131:16,19 132:13 133:21 137:16 138:21 139:24 143:23 146:19 148:10 149:21 158:10 162:24 good 6:7,8,10 21:17 68:1 76:3 122:16 138:4 151:13 156:11 government 68:7 governments 45:8,25 67:3 67:20 143:12 granting 99:22 Gray 149:12 great 25:19 54:20 56:7 122:1 greater 75:24 Greer 1:8 3:11 41:24 137:24 138:6,15 140:2 151:14 154:12 154:25 grievance 102:5 group 1:8 2:23 36:3 43:6 44:7 44:16,18 57:22 62:9 88:16 96:1,8,19 102:15,18,20 111:3 124:12 124:18 128:8 138:23 146:12 guaranteed 45:21 guess 32:8,24 36:1 50:6 72:15 84:5 88:24 132:20 152:1 157:5 guessing 47:10 guidance 147:19 guilty 41:19 guise 67:5,19 Gulf 1:7 2:16 4:13 6:18 7:1,5 7:12,19 8:4,13 8:24 9:3,10,15 9:21,25 10:5 10:10,14,22 12:6 14:1,18 14:23 16:2 18:23 27:2 29:20 73:21 79:4 84:7 87:24 88:14 95:21 97:14 98:7,22 104:12 109:6 125:24 126:7 127:3,21 128:13 131:6 132:10 135:4 137:5 142:18 142:19,25 143:1,3,10,13 143:18 144:17 144:21,25 145:2,7,13,23 146:8,10,15 148:1 149:16 150:2,18,23 156:21 157:1 11 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 162:6 gun 68:13 guy 29:7 107:10 109:12 H H 4:9 5:1 habits 40:22 hac 85:3 half 20:16 30:9 hand 24:3 handbasket 67:18 handed 8:10 88:12 137:3 handle 32:1 126:15 handling 88:25 148:19 handwritten 76:23 85:20 Hanna 40:7,13 41:5,8 58:23 58:25 59:1,10 59:15,16,20 60:21 61:11,16 62:9,19 72:21 74:7,15 75:14 76:14,25 77:6 77:12,19 78:15 78:20 79:17 80:2 81:10 82:9,17 83:22 84:22 85:12 happen 68:14 70:19 happened 50:20 103:15 113:11 133:9 136:1 157:13 happening 69:6 146:9 157:15 happens 156:17 happy 30:10 hard 40:22 109:11 he'll 158:11 hear 19:6 121:15 134:8 heard 67:13 hearing 112:15 139:12 held 13:14 40:16 103:8 108:20 142:6 144:14 hell 67:18 help 84:11 147:17 hey 139:9 hints 82:1 hip 74:20 84:25 hire 32:3 97:21 97:25 104:16 104:21 hired 32:1,5,7 98:21 110:1,2 111:7 112:18 126:14,15,19 Hochman 2:10 2:12 7:14,18 8:22 11:17 12:2,6 13:1,24 40:18 56:21 58:22 87:13,14 87:17 142:4 157:21,23 158:2,5 hold 39:17 153:8 holding 109:17 home 6:11 hone 11:10 honest 70:3,4 hoped 150:3 hoping 48:1 horse 48:4 hour 20:16 hours 53:8,9 115:12 162:15 huge 108:19 hundred 20:24 49:14 112:9 146:4 147:6 151:1 hundreds 102:16 I i.e 148:20 idea 45:2 103:3 119:13 Identification 8:5 23:12,22 37:8 73:12 88:10 120:18 125:3 identified 10:20 85:10 121:23 127:22 137:7 identify 7:8 123:11 identifying 95:13 110:9 illegal 151:3 imagine 142:16 immediately 31:9 103:13 impacting 70:25 implicate 94:6 imply 57:3 important 65:1 imposing 134:23 impossible 109:1 150:14 impressed 119:24 improper 155:18 imputation 39:14 inaccessible 147:9 inactive 79:4 include 36:4 44:8,17 included 116:19 139:3 140:6,10 includes 6:19 including 9:16 38:25 43:2 88:17 124:13 124:18 134:17 146:21 incorporated 42:12,14 78:24 79:24 80:12 105:12 increased 130:24 incurred 67:7 114:8,9 149:6 indicate 77:12 indicated 62:4 101:23 133:3 indicates 67:8 individual 6:24 45:6 individually 52:6 85:6 128:6 individuals 65:16 68:25 121:9,22 124:13 inextricably 74:20 inflammation 100:25 inform 135:4 informant 55:17 72:1 95:21,22 104:25 information 9:9 9:20 11:13,20 11:22 14:25 18:25 101:15 116:20 118:12 121:5 140:3 informed 55:20 135:2 initial 100:9,10 100:16 104:15 110:16 112:24 120:23 121:4 123:23 127:2 127:10,11 initially 32:5 105:16 108:5 151:23 injunction 110:12 148:8 148:11 149:4 injuries 154:4,5 input 107:21 inquiring 118:4 inside 26:24 insidious 67:11 insist 67:23 insisted 136:5 inspection 25:15 instance 19:19 21:4 26:18 integrity 66:4,18 66:21 67:8 68:9,24 69:3 69:25 70:9 71:7 72:16 intend 149:16 intentions 150:2 interested 161:19 interests 114:2 interim 107:5 interning 71:24 interrogatory 48:16 91:9 interrupt 76:7 Interruption 13:13 40:15 interview 18:19 40:14 49:9 50:6 141:1 interviewed 49:10 92:14,16 110:7,7,25 intimidate 83:7 introduce 7:10 136:20 137:2 introduced 134:13 invading 125:16 investigate 46:9 110:1 investigated 152:9 investigating 31:22 53:24 54:12 55:25 12 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 56:11 57:4,15 58:2,4 60:1 61:5,5,14 64:14 78:2,5,7 81:11,16 95:12 96:13 130:10 137:14,20 investigation 9:15 29:7,22 43:18 52:20 53:2 57:6 68:22 79:2 90:18 109:23 130:1 investigative 91:12,15,25 92:5 106:18,21 investigator 83:7 investigatory 104:15 invoice 4:21 30:23 73:7,11 73:16 83:25 invoices 29:19 30:1,3,8,13,16 30:21 31:6,14 31:22,23 73:2 142:10 invoke 118:19 involve 35:12,14 involved 21:24 44:2,4 45:7,14 59:6 61:24 62:2 63:2,4 65:16 66:13 67:16 69:21 75:24 85:4 101:7 110:2,5 110:20 111:19 113:9 116:16 116:24 119:17 131:1 139:9,11 148:13 151:21 155:1,5 involvement 12:6 19:8 45:24 52:10 54:22 55:3 65:11 81:21,25 105:8 110:17 113:6 120:13 129:25 134:19 154:22 involving 32:7 33:17 45:10 104:25 105:6 120:12 ironically 103:21 isolate 19:8 128:10 isolated 11:4 47:6 issue 31:14 76:1 78:20 80:7,18 80:25 100:3 105:7 112:5 114:2 116:13 147:4 issues 79:11,16 103:25 104:24 105:6 110:3 133:4 146:21 item 52:15,15 J January 159:12 161:21 162:9 JEFFREY 2:10 Jerry's 157:2 Joanne 72:21 74:1,7 76:15 76:25 85:13 112:1,4 153:2 155:3 Joanne's 83:17 job 71:24 99:18 Joel 9:20 29:8,8 41:5 44:23 45:4,5 47:2 53:5,20 69:25 70:16 71:4 95:22 104:8,17 104:19,22 105:2 129:10 130:7 139:2,9 139:16 140:21 141:1 Joel's 70:17 JOHNSON 2:11 joined 74:20 84:25 joint 85:1 Jonathan 53:3 79:3,6 85:2 93:11 101:19 117:20 118:8 118:11,15 119:3,6,16 120:6,8,11 122:23,24 Jones 42:4 72:21 72:23 74:6 78:12 131:22 Jordan 3:4 151:14 162:25 Josh 24:1 37:25 38:3 Joshua 3:14 162:24 Journal 109:5,5 judge 101:21 133:2 136:2,13 136:17 147:13 149:3 judges 38:24 67:15 155:16 judgment 131:7 133:2,8,8,14 134:9 135:12 July 45:2 46:7 46:12 47:1,4 49:11,17 52:22 54:2 72:20 73:1,3,20,24 76:25 78:1,11 78:13 79:17 81:3,9,18 82:16 84:7 104:8,9 105:2 jump 76:24 Jumping 76:12 June 30:14 juries 38:18 134:17 K keep 13:10 56:3 67:24 71:22 105:10 132:17 134:12 136:11 139:16 keeping 16:9 kept 110:18 key 142:15,16,16 kill 45:19 67:1 kind 18:3 68:4 111:8 KISSANE 3:15 knees 101:2 knew 19:4,5 46:24 55:19 82:4 89:13 112:19 133:7 155:3 know 11:2,23 12:11,11,11,14 13:17 15:15 16:1,17,19,22 16:22 18:11 20:25 21:22 22:2,11,14,22 23:2 24:17 27:22 28:12 30:1,4,12,15 31:17,18 33:11 33:14,18 37:16 39:2 43:19 47:9,11,12,15 47:16 53:7 56:2 58:23 61:13,14 63:20 64:16,23 65:18 71:2,20 72:3 74:19 75:6 77:25 78:14 79:10 81:19,23 82:4,9 83:20 85:5,18 86:4 87:18 88:2 89:10,14 90:4 91:20,23 93:21 93:22 94:23 97:11 100:2 101:10 103:15 106:3 107:10 109:4,8,10 110:6,8,22,24 112:18 113:6,8 113:11,12,17 115:6,13,17,22 116:16,22 117:3 121:1 122:12 127:15 128:16 131:13 131:20 132:23 133:17 135:18 135:22 137:24 138:10,11,17 139:5,15,21 140:5,9,9,11 141:22 145:12 154:16,20 knowledge 38:19 45:22 118:12 119:20 137:19 140:17 146:17 154:24 known 9:9 knows 12:10 116:15 Krenchicki 1:19 159:8,15 161:6 161:24 162:22 L L 2:10 6:1 lack 67:8 68:9 68:24 69:3,24 71:7 lacks 70:8 laid 96:24 Lakeview 3:16 language 96:5 lap 110:4 13 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. large 1:23 101:2 larger 22:18 Las 3:8 Lauderdale 1:13 2:7,14,21 3:9 162:14 laughed 83:5 law 2:5 6:2 15:21 16:12 26:13,24 31:9 32:15 33:1,12 41:13 67:12,16 67:20 68:9 69:13,15 70:25 71:23 73:17 78:14,21,22,25 79:6,7 80:6,11 80:25 87:7 100:3,6 101:16 101:17,20 102:8,19 103:25 104:18 105:7,9,10,14 109:17 112:10 113:13 115:24 119:19 130:25 133:23,24 135:2 137:13 137:20,24 138:15,18 140:2 143:8,17 143:20 144:19 148:18,24 149:1 150:12 150:19 151:15 154:6,8,25 155:18 156:5 laws 69:7 70:10 107:12 114:13 lawsuit 9:17,22 16:6 20:7 27:17,18 90:25 91:4 93:2 101:8 109:24 109:25 110:2 114:6 128:13 129:12 137:15 137:22,23 138:20 139:23 142:13 145:5 145:24 146:7 146:18 148:2,3 149:15 150:3 151:16 155:20 156:11 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133:15 134:7 134:11 135:9 135:23 143:24 needed 50:3 15 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 72:11,12 108:14 needs 120:2,3 Nesbitt 38:21 never 20:14 22:21 40:12 41:3,14,16,18 41:20 43:13,19 43:24 44:3,13 62:12 81:15 92:12,14 120:11 129:17 142:14 new 28:11 92:18 News 92:17 97:9 newspaper 11:4 night 19:23 36:23 37:12 38:7 104:10 nine 24:7 non-privileged 25:13 32:22 noncompliance 67:4 nonstop 71:13 Northeast 6:14 not-for-profit 42:16,23 69:10 103:9 116:2 notarial 50:7 Notary 1:22 159:10,18 note 8:6 122:3 notebook 51:21 noted 38:10 notes 13:4 161:14 nother 90:22 notice 1:23 4:12 7:10,20 8:3,12 38:13 117:19 118:2,8 119:4 notify 133:18 notion 66:9 Notwithstandi... 32:20 novel 156:4 November 1:14 21:9 159:11 novo 103:9 nuance 150:9 number 4:11 5:3 17:21,24 25:6 25:7 27:14 29:16 31:21 32:13,14 44:23 51:13 59:16 78:22 99:15 110:10,13 122:9,20 123:3 123:9,18 125:22,23 129:8 132:18 133:19 134:6 135:11 146:21 numbered 126:16 numbers 4:18 23:17,21 24:3 O O 6:1 O'Boyle 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117:7 156:14 opened 22:21 16 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. operate 22:22 30:25 operating 143:8 143:14,21 operational 30:23 opinion 43:17 66:8 67:24 70:7 71:10 114:14 118:24 140:7,8,12,13 140:14,20 141:14 opinions 66:2,4 66:18,21 129:25 opportunity 134:16 152:15 opposed 12:3 94:12 opposing 38:25 64:18 74:1 81:6,8 96:16 oral 39:11 40:6 40:12 88:3,5 139:20 order 13:6 46:20 67:4 108:15 123:15 136:9 136:12,15 150:13 158:8 ordered 157:24 157:25 158:5,9 ordering 158:2 162:19,20 organizers 144:22 original 24:11 24:22 136:12 160:24 162:19 originally 76:21 101:12 ought 77:8 outline 106:25 outrageous 64:24 68:5 outside 84:14 94:15 95:10,20 95:24 96:11,23 154:25 overcome 134:22 owned 131:11 P P 6:1,1 P.A 1:8 2:5,12 3:6,11,15 P.L 4:22 73:12 73:18 162:10 p.m 1:14 159:1 162:15 PA 137:24 page 4:2,11 5:3 38:5 49:15 73:23,24 160:2 160:5,8,11,14 160:17,20 pages 161:13 162:15 paid 31:1,3 54:25 71:15 130:20 Palm 3:17 72:22 89:23 paper 93:5 145:9 145:16 papers 80:13 92:10 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157:3,4 157:9,10 scratch 122:15 123:3,16,25 scratched 124:6 se 37:21 39:13 39:14,21 162:11 search 11:24 26:9 27:22 47:17 searched 18:23 18:24 47:24 second 73:23 secret 136:11 Secretary 28:4 section 129:2 sections 113:11 113:16 see 10:24,25 11:6,9 16:10 16:13,24,25 17:1 18:25 19:25 33:14 38:8 51:24 52:2 72:1,9 75:11 84:8 116:11,14 121:8,10 134:13,17 136:25 147:16 150:25 153:11 153:14,15,22 153:22 154:1,8 seeing 11:3 24:19 89:3 93:3,4 117:2 128:9 145:15 153:16 157:14 seek 148:3 149:16 seeking 35:5 108:7 131:24 146:5,23 seen 8:15 24:13 68:5 84:1 88:19 89:3 93:8,9,12 98:5 101:22 117:14 118:2,7 120:23 125:8 127:24 128:2 130:23 141:20 155:11 segue 17:3 send 30:25 sending 33:8 sense 114:25 sent 10:1,1,6,7 30:24 31:6 47:9 50:19 80:12 89:2 108:4 127:5,6 127:10,21 141:16 162:9 sentence 32:20 Sentinel 92:15 separate 32:2 21 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 60:1 74:22 84:15 136:6 152:2 separately 83:19 84:24 113:7 September 60:8 60:18 61:8 62:8 63:23 76:12 78:9 84:8 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92:8,13 109:23 121:12 speaking 50:18 91:14 92:5 116:7 130:9 142:18,25 150:1,2 speaks 25:17 37:24 40:2 121:17 149:21 Special 98:25 specific 11:10 18:5,6 83:2 99:4 117:16 121:9 130:12 130:15 specifically 62:6 78:21 126:15 specifics 13:19 83:12 speculate 70:22 75:4 speculating 70:20,24 speech 69:2 spent 24:6 53:8 53:9 142:11 sphere 27:13 spit 150:21 spoke 11:17 14:18 59:16 81:6 92:12 94:17 103:14 106:4 129:17 spoken 26:2 43:4 46:13 48:22 49:6 53:16 59:15 93:13,16 93:21 120:11 spout 153:12 St 162:11 stack 20:3 staff 18:9 26:1,9 stage 81:1,4 stamped 73:20 standard 50:9 standing 80:16 standpoint 30:23 Star 92:14 start 15:12 24:10 104:3 156:17 started 16:8 46:7 101:15 102:24 103:2 starting 153:15 starts 121:8 starving 141:24 144:1 state 1:22 28:4 45:11 46:1 22 Fort Lauderdale, Florida 954-755-6401 Daughters Reporting, Inc. 56:10 66:25 68:6 70:15 78:24 81:11,14 81:15,17,22,25 82:5,10,11,14 82:15 88:24 89:22 114:1,2 114:2,11,21 115:17 117:6 131:3 143:18 145:18 146:10 146:16 147:23 150:19 155:12 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