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
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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
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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
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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
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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
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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?
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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.
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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,
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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.
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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.
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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
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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
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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.
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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
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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?
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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.
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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
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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
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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
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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
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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
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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.
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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?
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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?
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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.
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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
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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.
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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
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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
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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
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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
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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
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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
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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,
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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
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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.
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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.
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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
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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.
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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?
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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
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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
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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
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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
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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
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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
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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?
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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
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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
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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,
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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
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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
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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:
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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 --
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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
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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
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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
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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
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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
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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
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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.
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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
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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.
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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
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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
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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 --
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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
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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.
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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
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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,
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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
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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
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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
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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 --
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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?
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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
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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
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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.
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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
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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
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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,
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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
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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:
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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.
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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
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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
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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
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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
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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?
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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.
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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
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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.
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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.
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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
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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:
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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
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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
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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
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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)
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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
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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
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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?
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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
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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
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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
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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:
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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
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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.
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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?
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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
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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
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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
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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
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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
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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
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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
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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
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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.
A
a.m 1:14 162:15
abbreviated
12:8 127:1
ability 45:18
able 9:7 45:14
52:25 77:8
104:21 119:18
134:17
abnormal
111:16
absolute 69:14
134:18 156:9
Absolutely
142:22 153:10
abuse 58:2 61:15
69:5 99:20
100:5,6,25
111:13 112:5
abuses 70:21,21
70:23
abusing 70:10
abyss 141:21
accelerated
99:17
access 15:16
156:15
accident 154:3
accidents 69:10
accommodate
142:4
accurate 47:8
50:21 152:21
accurately
143:18
accusation 39:15
accused 39:25
40:1 42:24
96:20
accusing 43:20
acknowledgm...
77:19
act 57:9,22
63:10,14,17
64:2 96:9 97:4
115:2 155:19
acting 155:6
action 54:12
56:12,18 57:16
108:14 134:9
136:24 137:4
146:9 161:19
161:20
actions 107:11
131:8
actively 79:6
activities 15:13
15:22 16:16
44:2 65:17
72:8 81:21
92:23 119:18
activity 44:4
67:9
acts 56:25
107:13
actual 18:18
22:18 51:25
77:19 99:4
107:6 125:21
actuality 99:23
add 30:7 115:10
137:9
addition 49:21
additional
106:16
address 6:12
102:19,19,20
addressing
116:24
adjudicated
132:3
adjudication
132:6
administer
147:17
administering
131:12
admissible 77:10
119:15
admission
125:22,23
132:4
admissions 5:8
124:24 125:2,7
125:12 129:9
admit 125:24
126:5 129:10
129:15
adopted 156:6
advice 119:10
advised 15:12
affidavit 10:18
13:12,18 19:4
19:13 20:12,13
20:15 21:6
28:6 47:7 49:9
49:22,25 50:10
50:15,23,24
51:5,8,10,12
affiliated 15:9
15:24
affirmative
108:12
affirmed 147:12
afternoon
151:13
agencies 33:2
41:13 46:5
agency 32:16
33:12 87:8
91:11
agent 71:12
132:17
agents 99:6
ago 19:25 30:9
58:12 98:19
agree 34:13 40:9
137:6
agreeable 25:15
agreed 21:14
35:22 97:21
116:11
agreeing 76:19
agreement 25:1
25:2 59:23
60:15 76:23
77:3 85:17
86:16 139:20
149:8
agreements
148:16,23
ahead 23:5
29:16 37:4
76:12 88:6
aired 111:5
al 6:19 162:6
Alexandra 92:12
allegation 40:9
allegations 9:11
32:16 33:2
89:8 90:2,6,25
91:3 92:7 93:1
93:20,22
107:16 152:21
allege 41:12
alleged 59:9 61:6
61:6 105:9
111:21 130:21
131:1,9 142:20
144:23
allegedly 19:16
80:15 131:12
alleging 108:13
allow 129:15
137:25 162:16
allowed 87:11
153:12
allows 148:14
alteregos 15:24
99:6 103:7
amended 4:17
4:20 23:15,19
32:11 36:25
37:7 91:10
amount 112:19
amounts 54:25
analog 153:14
analysis 15:22
16:12,15,20
17:2 52:19
analyzed 21:16
analyzing 95:12
112:14
anarchy 67:15
and/or 10:1,6
27:17 29:20
32:15 41:13
47:13 126:1
ANSELMO
2:11
answer 11:25
19:9,11 29:23
30:17 54:10
60:12 85:8
86:3 107:23,24
118:6 122:2,7
125:16 137:18
answered 43:23
58:8 60:22
61:12 105:17
106:20 121:25
126:10,22
127:8 129:3
137:16 138:12
139:24 146:19
answering
110:22
answers 9:2
133:13
antenna 102:22
anticipated
101:11 117:4
132:14
anybody 19:6
63:2 93:10
110:25
anyway 36:16
apart 60:2 74:22
apparently
103:7
appeal 133:7
appeals 147:4
appear 29:9,14
88:18 100:18
appearance
100:15
APPEARANC...
2:1 3:1
appeared 159:10
appears 37:13
37:15 73:16
87:24 88:15
appellate 155:14
applies 68:17
apply 69:25
2
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
appreciate 23:1
23:4
appropriate
7:13 66:25
137:21
approvals 100:7
approve 153:13
approved
127:16
approximately
137:7
April 4:23 30:14
32:8 62:24
88:9,17,20
97:23
arbitration
102:6
area 7:17 12:15
104:23
areas 8:1 11:11
11:21 107:15
argued 115:18
arguments 120:2
arithmetic
136:22
Aronberg 88:24
89:17,18,22
90:1,5,10,12
90:19,20
arrange 162:13
article 28:10
46:23,23 91:21
92:18 109:5,6
articles 11:4
28:11 93:4,4,9
93:23 97:11
artifice 143:9
ascertain 45:14
asked 11:11
19:24 25:20
29:5 43:23
47:7 48:24,25
52:7 58:8
60:22 61:12
65:2 91:19
103:16 104:13
104:16,20,23
105:17,18
106:8,20
107:18 113:17
121:25 122:23
122:24 126:5
126:10,22
127:8 129:3
137:16 138:23
139:24 146:19
151:24
asking 18:3,10
18:11 41:10
66:20 72:24
91:18 105:2
108:5 118:21
118:23 156:20
asks 25:7 27:14
29:19 32:14
125:23 129:10
aspect 18:23
assembled 20:3
21:20
asserted 39:21
152:25
asserts 37:21
assessing 142:11
assist 100:22
125:25 126:7
126:19
associate 112:2
115:15
associated 36:7
49:15
associates 18:17
assume 17:17,20
26:23 27:1
31:23 44:24
51:4 54:10
59:14,14 77:2
140:21,24
141:3,7
assuming 138:8
assumption
134:25
assure 30:22
65:8
assured 54:18
attacking 80:15
attempt 67:5
129:19 130:3
attempted 70:6
attempting
108:21 131:8
attend 73:25
attorney 17:18
17:21 18:7
21:18 31:8
33:13,17,19,25
34:8 35:2,19
81:11,15,16,17
81:22 82:1,5
82:10,11,14,15
86:18,22 88:25
89:23 94:21
117:18,22
119:9,23
137:20 153:12
161:16,18
attorney's 17:14
45:12,21 67:6
67:22 80:20
94:7 101:3,5
146:2 148:14
attorney/client
125:16
attorneys 27:5
41:25 42:1
45:11 99:1
100:23 134:6
154:25
August 37:1
73:1 82:17
83:11,24,25
84:5,8,17
authority 80:6
101:25 104:14
105:3,15,23
106:13,17
108:6,7
authorization
108:1
authorize 105:19
106:7,7
authorized 10:1
10:6 90:13
98:21 102:10
161:10
autistic 67:2
available 9:10
20:19 25:14
27:20 29:24
49:1 110:11
141:9
Avenue 1:12 2:6
2:20 3:16
162:14
awaits 162:13
aware 17:5,8,11
17:14 28:17
33:5 44:21
49:3 53:23
58:15 86:21
87:6 92:24
93:24 94:14
95:5,24 96:7
96:17 97:1
106:24 117:18
127:20 128:1
128:12,18,19
129:19 130:19
131:3 139:1,19
142:10 145:4
145:17,22
147:25
Awareness
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
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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
38:17 41:2
43:8,25 47:1
47:19 48:7,18
50:17 52:23
53:22 54:1,13
55:8,12 56:12
57:2,4 60:14
60:19 63:20
64:5,14 65:10
65:12,15,24
66:14,17 71:4
74:5 75:14
76:13 79:16
80:2 82:18
85:13 91:9
92:11 104:9
107:2 108:4
117:9 118:11
118:15 119:6
123:7 125:13
127:19,24
128:5 129:4
133:1 135:10
136:22 138:22
142:19 143:1
143:14,16
144:17,21,25
152:20,23,24
153:11 156:7
believed 15:9
56:25 95:14
99:3,16 135:23
143:13,19
believes 66:24
beneficial 14:11
Berger 21:23
BERNARD 2:19
best 16:4 22:19
23:2 50:9
87:21 132:20
132:20
better 72:17
115:9
beyond 53:15
150:1
Big 65:13
bill 81:6 84:4,5
84:10
billing 38:11
bills 83:20 84:6
84:9
bit 94:24
blew 139:10
blurted 58:12
board 111:7
Boatlift 72:1
Boca 6:14 82:18
162:11
bona 57:5 64:14
79:13,14
101:17 155:7
book 72:5
borne 51:25 56:9
bottom 38:12
73:24
Boulevard 2:13
3:8
bounce 116:10
boxes 18:13
bragged 45:18
brain 82:21
break 33:22
40:23 141:23
143:25 144:7
briefly 8:17
82:23
bring 136:4
bringing 101:1
broad 114:10,14
broad-brush
12:13
broader 100:17
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
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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
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ethically 109:19
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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
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154:11
EXAMINED
6:3
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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
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138:4 156:11
fake 114:19,20
fall 15:7 16:2,7
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44:24 45:1
81:23 82:13
102:7
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77:21 84:7
85:18 111:4
127:15 138:17
139:15 140:18
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fast-moving
61:24
favor 31:13 32:9
fax 99:25
February 15:20
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105:12
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85:4 114:22,25
115:21 117:7
149:2 162:18
fee 148:15,22
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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
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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
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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
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firm's 98:23
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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
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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
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G
gambit 27:13
Ganger 123:18
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gather 25:22
gathered 25:23
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general 12:12
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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
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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
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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
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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
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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
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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
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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
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65:16 68:25
121:9,22
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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
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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
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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
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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
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keep 13:10 56:3
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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
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known 9:9
knows 12:10
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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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20:25 45:20
71:6 79:23
99:11,15
100:12,16
105:13 115:3
126:1,8,20
135:3,5,11,19
145:2,6,20,25
149:18 150:17
lawyer 24:2 59:1
59:8 62:14
66:13 67:25
72:11 79:8
80:9 96:16
114:17 116:3,8
125:19 130:14
141:16 154:3
157:7
lawyer/client
27:13 31:11
lawyers 27:7
32:18 38:25
55:24 67:13,14
68:4 69:14,18
69:20,21 77:14
115:3 116:23
138:5 148:13
153:19,20,20
155:9 156:2,3
156:11 157:6
lay 82:3
lead 119:14
leading 29:7
learned 45:6
46:4 56:5
67:14 102:13
103:1 108:11
110:18
learning 102:15
110:18
leave 36:7
lectured 154:17
lecturer 103:22
left 147:20
legal 9:5,6 29:20
38:15 43:17
61:16 62:15
63:22 64:17
67:17 68:12
69:4,5 113:19
114:7 115:6,8
116:13,18
118:24,24
120:2 123:10
126:12 133:12
135:7 138:18
140:12,20
141:14 143:9
152:24 153:1
156:24
Legislature
69:16 71:1
155:17
length 81:7
Lenore 38:21
let's 10:24 17:3
24:10 29:16
42:11 52:22
55:15,16 60:3
63:4 77:7
142:4 144:12
letter 33:14,23
34:5,10 35:19
36:11 86:19
87:2,4 97:14
97:16 98:4,11
107:1,4 127:1
127:5,10,13
129:20,20
162:17
letters 93:11
Levin 114:10,12
114:16,20
liberal 70:14
license 101:20
lie 67:21 143:10
light 55:20 65:21
84:25 85:1
90:17
lilly 71:20
limit 95:17
limited 99:16
100:11
limiting 70:13
94:9
line 104:7 160:2
160:5,8,11,14
160:17,20
link 22:2,4,20,24
list 121:3,21
123:12 124:7,8
124:12,17
139:3
listed 91:11
122:20 123:9
123:24 162:20
listen 110:6
114:10
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litigation 12:7
16:18 32:2
38:23 47:14
59:11 69:14
71:14 88:15
112:17 114:3,4
116:1 117:5
118:13 148:13
150:5,11 156:9
little 31:10 94:24
134:20 142:2,3
living 38:23
locate 18:10
located 34:16
log 15:12,17,18
16:3,6,9,17,21
36:11,15
logs 10:22 14:23
16:1 127:25
128:4
long 24:7 34:25
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long-standing
66:6
longer 144:2
look 11:23 16:13
16:24 19:11
20:1,14 21:2
21:19 24:15
26:16 30:14
32:13 34:15
35:24 37:14
50:13 73:9
75:11 83:20
84:5 85:5
107:9 116:12
125:21 126:13
128:3 131:17
137:1 149:13
150:23
looked 10:24
11:5,9 13:17
16:10,11,25
19:19,25 20:7
20:17,18,19,23
22:21 28:12
38:8 84:1 89:4
105:8
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80:19,22 96:14
100:4 115:1
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looks 116:14
losing 38:18
lot 67:13 68:15
82:6 92:8,9
Lou 76:14 85:13
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lunch 141:23
Lutheran 67:2
M
machine 99:25
maintained
138:4
maintaining
15:12
maintains 26:15
14
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
40:4
major 116:17
majority 48:8
making 40:1
45:7,9,11,16
46:1 95:25
143:2,5 154:5
155:6,7
malicious 111:14
114:15
manager 101:24
104:2 105:19
105:25 106:7
106:10 107:19
manner 18:12
147:2
manufacturing
66:25
many-hour
53:12
Mariel 71:25
mark 23:6 37:5
41:5 58:23,25
59:1 74:7
76:13 85:12
88:7 120:14
124:21
marked 8:5,11
23:12,14,22
37:8 58:22
73:12 74:3
88:9 120:18
125:3
Martin 99:5
121:8 126:1,8
143:20
MARTINI 1:4
162:3
Marty 49:2
mass 67:3
massive 112:19
materials 45:17
matter 27:16
30:6 32:6
35:10,15 36:12
52:9
maximum 106:6
Mayor 40:19
41:2 85:12
87:25 101:24
103:14 104:2
105:19 106:1
107:18 157:10
MC 3:6
McMillan 147:5
mean 12:23
29:12 63:1
64:13 100:14
104:20 108:10
128:6 130:13
142:15
means 77:16
145:19
mechanisms
69:23
media 90:24
92:6 93:1,14
93:17,20,22
97:7
mediation 59:24
76:22 77:5
85:8,22
Medicaid 153:23
Medicare
153:23
meet 72:20
82:17 154:8
meeting 49:19
53:15 60:6
73:25 74:12,14
74:25 75:2
76:13,18,25
77:3,25 78:1,9
78:12 79:18
81:9 82:16
83:10,23 84:3
84:17,19 85:11
85:16 86:1,6
86:13,15 97:15
97:18,19,20,24
98:2,17 110:21
127:16 129:22
meetings 9:20
74:15 75:12
153:4 157:2,4
member 90:24
92:6,25
members 14:17
memo 117:15
148:17
memorandum
141:15,18
memos 116:23
117:9,10
men 69:19
mention 48:13
56:16 58:1,3
81:14
mentioned 14:22
20:11 28:9,12
44:23 56:15
82:12 86:2
92:1 104:13
127:12,17
mentioning
95:19
mentions 109:6
Merit 1:21 159:9
159:17 161:8
meritorious
152:25
met 53:5,7 54:4
74:6,18 84:22
104:7 105:1
113:2,14,14
117:11
middle 24:21
Miller 26:12
mind 43:13
52:17 56:3
71:22 92:9
105:10
mine 89:14
minions 109:16
minutes 97:15
97:18 98:10,16
126:13 127:15
127:18 144:4,8
Mischaracteri...
98:9
missing 84:9
mistaken 104:10
113:24
mix 102:22
112:14 139:16
modified 156:9
moment 22:7
23:3
Monday 19:23
20:5 162:15
money 45:9
54:25 55:6
99:22 149:1
150:15 153:21
monies 45:24
67:5 130:19
month 19:14
65:2 72:24
73:3
month's 109:4
months 50:3,11
50:12 58:12
Morgan 14:3,4
40:19 41:2
76:16,17 85:12
87:25 88:16
93:16 122:20
157:10
Morgan's 93:8
morning 6:7,8
89:5 151:20
motion 50:25
78:13,16 79:14
79:20,25 86:11
94:16 95:6,25
101:22
motivation 56:5
146:15,17
147:25
motivations 9:15
motive 145:23
Motors 43:14,15
mouth 73:7
moved 38:12
multibillion
153:24
multiple 136:21
137:10
multiplier
148:21
MURDOCH
2:12
mutually 25:15
N
N 4:1
name 19:16 25:9
25:11,24 26:6
26:21 27:15
28:8 29:9,13
35:12 40:12
41:4,7 43:20
81:8 86:2
89:21 93:3,5,8
95:20 102:17
105:14 117:11
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128:10 129:11
137:25 139:17
139:22 140:1
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named 69:11
102:15 126:15
128:14 131:4
131:15 132:11
136:23 137:21
names 112:8
121:3,21 124:7
124:8,12,17
naming 9:21
129:18,18
narrowed
114:12
nature 104:5
NE 1:12 2:6
162:14
necessitated
136:19
need 30:18 84:5
94:21 131:24
132:15 133:11
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
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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
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O'Boyle 15:4,10
15:23 17:23
19:15 21:25
22:17 45:15
46:25 52:4,6,7
53:3,4,25
54:23,24 55:3
55:4,21 56:4
56:13,16,19,25
58:11 59:5,6
61:2 64:25
65:10,12,23
66:12,19 68:20
71:11,16 74:21
74:23 78:14,22
78:25 79:6
81:14,25 84:25
85:2,7 90:18
90:21 91:1
92:23 93:12
99:5,21 100:3
100:25 101:16
101:17,19
102:19 103:4
105:9,10,14
108:18 109:15
110:23 112:10
113:13 117:20
118:9,11,15
119:4,6,16
120:6,9,11
121:9 126:1,9
133:23,23
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59:5 70:21
71:15,16 81:21
109:12 140:15
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112:2
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56:17,19 57:7
57:9 59:3,7,10
61:1 62:1
68:20 70:4,5,6
74:20 75:22
76:14 84:24
85:3,5,13 93:9
99:5,20 100:1
103:6 110:23
113:4 126:2,21
129:11,18,20
129:21 130:3
134:3
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113:6 129:25
oath 52:7 65:4
159:4
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56:20 62:21
71:9 98:8
117:25 118:17
131:19 132:13
133:21 138:21
143:23
objecting 55:4
118:3
objection 7:20
7:22 126:3
148:10
objections 7:23
24:24 32:19
36:16
obligation 124:4
obtain 67:5
71:14 101:15
obtained 49:8,22
143:11
obtaining 45:12
146:21
obviously 18:14
29:8 50:5
63:19 79:5
100:8 108:11
110:10,17,20
122:4 128:21
146:7 150:7
occasion 91:20
occasions 59:17
136:7
occur 136:16
154:4 156:7
occurred 12:13
28:9 46:20
49:3 55:10
59:22 83:10,23
84:17 85:9
140:16 152:8
occurring 15:13
58:16 145:5
147:10 148:4,5
149:12
October 7:21
30:15 52:22
84:8
off-the-record
113:4
office 20:1 21:17
23:3 26:9
33:14,18,19,24
33:25 34:8
35:3,20 50:16
71:25 72:22,24
74:6 78:12
82:18,23 83:2
83:17,18,19,23
84:12,16,18
90:1,9 147:8
153:4 158:6
160:24 162:13
162:14
offices 33:11
113:15 117:12
officials 136:4
Oftedal 133:3
136:2,17
Oh 29:4 123:14
Ohio 59:2
okay 6:23 7:4
8:22 9:7 11:14
11:19 25:4
67:25 74:11
76:6,24 84:3
84:10 90:16
94:23 121:15
140:13 144:6
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old 40:22 147:6
once 162:20
ones 31:24
123:16 124:3,6
133:1 136:21
ongoing 36:8
46:9 55:14
65:23,24 66:1
66:7,7,10,15
onslaught 99:2
open 21:23
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
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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
parading 146:3
paragraph 32:19
98:14
paralegal 18:17
26:13 28:25
115:15
paralegals 27:8
parameters 60:3
96:24 122:6
Pardon 38:1
87:14
parent 79:1
part 19:16,17
25:22 29:10,15
56:5 67:9
102:21 103:10
108:25 109:22
126:14,18
127:11 142:20
145:23
partially 140:21
140:24 141:3,7
152:14,14
participant 72:8
participate
129:1
participating
119:22 143:2
145:1
participation
130:21
particular 12:15
12:21,25 73:8
120:10 137:13
137:19
parties 38:24
41:13,20,22
42:25 43:7
44:5,18 95:18
116:19 123:13
160:25 161:17
162:20
parties'121:6
161:18
partner 115:15
153:3
parts 151:3
party 24:7 26:7
26:19,20,23
43:21 44:9
62:19 63:6
96:1,8,18 97:2
122:15,19,21
123:1,17 131:5
131:14 132:9
132:24 135:20
162:19
passed 39:1
pay 150:16,22
pays 65:14
pedophile 49:2
58:13
pending 78:16
121:18 132:2
135:5,23
Pennsylvania
79:2,3 105:11
people 15:24
18:20 26:24
36:3 44:7,10
44:16 56:14
62:2 63:2,4
65:13 67:13
68:12,18 100:6
111:10 114:14
115:9 121:5
122:4 123:12
124:13,18
150:20 153:25
156:12,17
perceived 101:7
perform 39:16
performed 27:22
29:21 109:23
period 15:19
17:2 19:14
130:24
permission
103:16 104:2
104:16 105:16
108:15 131:8
permit 101:5
permits 99:22
perpetrated
69:18
person 46:17
48:22 53:6
57:19,22 62:9
87:6 92:25
93:24 94:15,25
95:2,5,24 96:8
96:18 97:2
106:14 113:12
137:13 140:15
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personalities
122:18
personally 53:14
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62:10
PETERSON
2:19
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phone 11:17
24:20 46:19
53:16 106:14
106:15
phrased 129:13
phrasing 129:15
physically 61:21
83:16,17
piece 52:12
pile 109:17
PIPER 2:12
place 112:12
115:19 116:21
plaintiff 1:5 2:8
9:12,16,22
10:2,7 19:1,5
29:22 31:23
41:14 44:8
114:19,20
128:14 150:11
154:1,2 162:4
plaintiff's 4:15
4:18,20 5:7
23:8,11,16,20
24:12 25:9,11
25:24 27:15
36:25 37:7
43:20 118:14
124:23 125:2,7
plaintiffs 69:9
69:11 85:1
player 142:17
players 66:13
playing 119:24
pleading 29:5
93:25 94:16
95:6,25 137:25
138:1 152:7
pleadings 11:5
26:6 29:10
50:25 133:13
17
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
Please 160:24
162:13
plural 66:4
point 20:8 34:8
36:8 49:10
52:21 53:23
58:1 60:12
66:20 73:8
74:18 78:15,17
81:13,20 83:13
84:2 87:3
101:23 103:1
portion 14:1
22:15
portions 128:25
position 65:7
79:14 80:4,17
possession 28:18
33:6
possible 61:20
possibly 26:17
48:5
Post 92:13
post-judgment
135:13
posted 31:10
poster 150:18
potential 31:22
55:25 57:16
potentially
81:11
practice 78:21
80:5,25 102:8
103:25 104:18
105:6
practiced 59:1
practicing 67:12
79:7 101:19
prayers 148:7
pre-summary
133:14 135:12
precedent
157:13
precedents
115:22
precursor
156:19
predicate 115:2
155:19
prejudice
135:15
preparation
8:18 125:11
151:21 154:23
155:1
prepare 10:14
15:21 96:14
109:24 110:8
110:15
prepared 10:9
10:22 11:25
14:23 16:13,14
16:24 50:1,17
76:23 77:3
116:23 127:1
129:5 154:12
preparing 11:15
13:25 16:3
26:5 96:13
prerequisites
156:18
present 47:4
153:4 157:4
presented
136:13
president 102:2
press 46:19,22
72:14
presumably
119:5
presume 30:5
36:20 52:5
98:1 134:4,5
138:5 148:8
presumptions
138:9
pretend 150:11
pretending
153:25
pretty 12:8,10
13:20 21:5,5
34:4 37:17
52:17 72:18
74:14 140:18
141:25
prevent 146:2,24
prevented
109:18,18
previous 98:9
previously 12:5
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75:9 87:1
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prior 15:19
16:23 24:17
75:11 108:1
109:23 122:6
157:1
private 45:8
131:10
privilege 36:11
36:15,16 69:14
114:3 117:5
125:13
privileged 29:3
48:10
privy 128:17
157:2
pro 85:3
probably 11:2,9
18:13,17 19:14
22:1 24:5,19
50:7,9
problem 100:21
156:17
proceed 135:17
proceeding 50:4
54:23 77:10
process 58:2
61:15 99:20
100:5 111:13
112:5
processed 149:3
processing
147:17
produce 21:14
25:1,3 32:21
34:17,19 35:22
109:3,11
produced 16:17
17:12,15,19,21
17:25 21:13
25:24 30:9
31:15 47:13,21
48:17 84:2,6
87:23 88:14
108:18 141:9
product 29:3,15
34:3 35:5,12
35:16 36:8
production 4:16
4:18 17:6
22:16 23:8,11
23:17,21 24:12
32:14 34:14
profession 39:17
professional
1:20 46:2
159:9,16 161:7
profited 140:17
program 153:24
project 119:13
prolific 32:1
proper 137:14
138:2,23
142:12
properly 155:7
prosecuted
133:10
prosecution
111:14 114:15
Prosecutor
87:21 88:25
89:7,11 90:12
prosecutorial
32:16 33:2,12
prospective
27:17
protect 130:3
protected 69:13
156:12,16
protects 154:6
provide 9:8
34:13 36:11
37:2 119:18
provided 7:8
9:20 10:17
13:8 17:18
18:4,6 20:18
20:22 22:9,10
22:24 26:10
29:20 30:1,4
45:18 47:13
52:15 66:24
94:4
providing 94:12
136:16
public 1:22 9:24
10:5 15:3,7,14
18:16 30:6
31:9 32:1,7
35:14 45:7,10
45:17 46:1,5
59:4,11 67:1
68:8 70:10,14
71:5,6,24
72:11 74:16
78:23 82:7
99:2,11,24
100:12,16
102:16 103:10
110:3 112:17
112:20 116:2
125:25 126:8
126:20 127:21
128:15 133:4
134:15 143:5
145:2,6,19,24
146:25 147:10
149:17 150:6,7
151:4 156:14
156:15 159:10
159:18
publication
39:11
publish 131:8
published 26:4,7
40:6 43:25
91:21
purported 36:6
42:19
purportedly
10:1,6
18
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
purports 42:13
42:15,22
purpose 74:11
74:13,25 75:7
84:19,23 143:9
150:14
purposes 11:19
17:18 18:23
45:3 49:7
pursuant 1:23
31:8
pursue 111:3
push 31:13
put 73:6 74:9
132:15 134:11
putative 146:8
Q
question 9:14,19
9:24 10:4
19:12 25:20
27:21 29:25
32:24 76:3,8
101:16 118:4,7
121:18,18
129:14 135:3
138:12 142:24
questioned 65:1
115:20
questions 12:1
19:10 41:10
48:25 76:7
91:18 110:22
111:8 144:10
151:8,9,18
154:21 157:17
157:18,20
quick 72:18
quickly 19:10
36:23 37:17
51:18 69:7
72:13 76:22
85:7 147:21
quite 104:6
122:19
quod 39:13
quoted 91:22
93:11
R
R 6:1,1
racketeer 62:13
64:22
racketeering
41:15 43:2
53:20 55:9
57:1,10,16
59:18 60:20
63:11,15,18
64:3 86:5
96:10 111:15
111:21 130:16
raised 32:17
33:3 75:8
raising 112:4
ramifications
103:17 104:4
rate 97:17 98:13
Raton 6:15
82:18 162:11
reached 66:3
85:17
read 11:7 21:3
36:2,20,22,23
37:3,16,16
38:7,9 40:3
51:21 66:23
109:4 114:16
115:11 121:2
129:21 145:8
148:17 157:23
158:11 162:14
reading 24:20
56:6 162:13
real 69:9,10,10
114:19
realize 156:3
realizing 82:5
really 12:18 13:5
31:20 42:8
43:10,13 66:19
75:22 79:19
88:2 102:7,21
112:20 121:14
Realtime 1:22
159:9,17 161:9
reason 72:13
83:19 84:16
135:12 160:4,7
160:10,13,16
160:19,22
reasonable
162:17
reasonably 9:9
109:2
reasoning 9:16
reasons 123:9
recall 12:20 17:9
17:9 18:1,6
20:10,16 24:19
33:16 46:21
49:25 53:14
57:14 59:25
60:6 61:9
74:24 77:21,22
77:22 78:19
83:11,14 84:18
89:6 90:8
91:14,17 92:5
97:22 111:4
117:17 130:7
139:4,6,13
151:22
receipt 162:17
receive 47:22
received 9:25
10:5 48:4,8
73:20 91:10
103:18 104:4
107:1,4 141:4
162:20
receiving 33:9
recess 76:10
142:8
recognize 115:25
119:10 146:24
153:18
recognized
69:16 79:24
102:21 117:7
155:10,14
recognizing
69:17
recollection
13:22 16:4
50:20 83:3
86:20 87:21
88:1,5,21,22
90:11,12,14
111:20 112:1
117:16 130:13
130:15 132:21
recommending
114:21
record 7:14,18
13:15 30:6
40:17,18 41:23
86:10 100:15
129:22 142:7
144:13,15
161:14
records 9:25
10:5 15:4,8,14
18:16 32:2,7
35:14 45:7,10
45:17 46:2
51:2 52:5 53:1
59:4,11 67:1
68:8 70:10,14
71:5,6 74:17
78:23 82:7
99:2,11,24
100:12,16
102:16 103:10
110:3 112:17
112:20 125:25
126:8,20
127:21 128:15
131:10,25
132:15 133:4
133:15 134:15
134:15,21
135:24 136:10
143:3,5 145:2
145:6,19,25
146:25 149:17
150:6,8 151:5
156:15
recounts 19:13
recuse 90:20
redactions 31:8
redrafted 113:2
113:16
Redweld's 11:2
18:25
refer 42:20
reference 162:12
referenced 19:18
20:10,20 25:9
25:25 27:15
28:7
referencing
25:10
referred 21:8
43:11 65:13
81:8,22
referring 36:24
42:7,18,19,21
89:11,18 97:19
106:11 156:1
157:9,10
refiled 65:5,22
refiling 65:6
reflect 7:18
40:18 142:11
refresh 88:21
refreshing 13:21
refusing 86:13
regard 15:13
21:24 26:2
33:20,20 34:3
35:7,9 45:23
56:1 70:3,4
71:2 72:15
95:4 99:2
101:9 113:3
140:15 162:18
regarding 18:15
52:10 53:3
54:22 55:6,13
66:3 87:8
88:23 89:7
90:1,5,18 92:7
92:22 93:1,22
96:12 113:19
19
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
118:8
Registered 1:20
159:9,16 161:7
regulate 147:1
reissue 136:17
relate 35:25 36:3
related 11:1 12:7
19:1
relates 36:5
135:3
relationship
31:11 46:25
65:23,25 66:1
66:7,10,15
relative 161:15
161:17
relatively 20:4
release 46:19,22
146:22
releasing 13:11
relevance 118:25
118:25
relevant 118:12
118:15 119:6
119:13 121:5
relied 9:21 51:4
relief 148:8
149:16
relocated 59:2
relying 51:8
remaining 124:7
124:8,12,17
remedies 107:13
remember 12:22
13:2 18:19
26:16 33:15
34:7 38:9
40:13 46:18,19
46:19,22 54:13
54:15,16,17
61:3,21 62:6
74:13 75:6,13
78:22 79:19,20
79:20 80:3,4,7
80:24 82:22
83:16,17,17,18
84:12,12,15
88:3 89:3
91:18 92:21
93:3,4,5 97:8
106:4,5,9
111:7,12,17
112:3,13
113:22 114:18
114:23 115:5
115:14,16,17
115:21 117:2,5
128:9 132:18
139:8,12
145:11,15,15
151:23
remembers 83:1
remuneration
119:21
repeatedly 52:7
56:5
report 90:14
94:22 161:10
reporter 1:20,21
1:21,22 49:18
50:8 90:24
91:17 92:6,20
92:22 159:9,9
159:9,10,16,16
159:17,17
161:1,7,7,8,9
reporter's
140:25
reporters 91:8
92:8,10,19
reporting 91:12
91:16,25 92:5
94:19 162:23
reports 97:8
represent 47:20
59:10 137:3
151:14
representation
97:17 98:12
100:11 104:12
representative
4:13 7:11 8:4
8:13 127:3
135:1 145:13
156:21
representatives
95:11
represented
51:24 52:5,6
59:3,5 65:18
65:19,20 78:25
representing
59:7 65:20
66:11,12 85:3
107:15 112:10
reproduce 30:10
30:19
reputations
39:10
request 4:15,18
5:7 9:25 17:6
23:8,11,16,20
24:12 25:5,7
27:6,14 28:20
29:16,19 31:20
32:13,14,23,25
74:17 99:4
124:23 125:2,7
125:22,23
129:8,9 143:6
146:25 150:6,8
requested
161:12
requester 127:22
requests 15:4,8
15:14 18:16
21:15 32:7,12
35:21,25 45:7
45:10,11,17,20
46:2,5 59:4
67:1 68:8 71:5
82:7 99:2,24
99:25 101:9
102:16 108:25
109:2 112:9,20
125:12 127:21
128:2 134:2
143:3 146:4
147:14 150:13
150:17,24
151:5
required 121:4
requirement
133:13
reread 11:4 19:7
research 113:19
113:22 115:6,8
115:18 116:17
153:3
researched
102:10 116:5
researching
61:14 62:5
95:13 113:10
residing 79:4
resist 136:17
resolve 77:9
respect 9:3 57:7
86:19,23 93:20
108:7 149:15
respond 109:2
134:7 135:10
147:2,13
responded 15:15
107:5
responding
147:20
response 4:15,17
5:7 23:7,10,16
23:20 25:12
27:19 32:13
40:8,11 124:23
125:1,6 126:3
129:13 154:21
responses 24:11
24:22 32:11
48:16 91:10,11
125:12,21
responsible
70:18
responsive 11:13
21:13 25:13,23
27:20,23 28:1
28:19 30:21
32:22,25 35:20
48:6,10
rest 147:9
restroom 76:4
result 45:21 56:6
70:21 130:20
150:5
resulted 15:5
retain 36:10
101:25 104:14
105:3,16 108:6
retained 5:10
15:17 98:6
99:10,10
125:24 126:6,6
retention 32:3
127:16
retracted 58:14
retrieval 21:25
returning 123:6
reveal 87:11,15
revealed 79:3
review 7:7,16
8:19 15:18,25
17:19 19:22
31:14 47:8
92:13 104:10
152:15 161:11
162:16
reviewed 10:16
10:17,19,22,24
14:22 16:5,9
22:16 24:17
35:21 37:11
68:21 82:13
98:16 125:14
152:18 155:5
reviewing 11:14
20:10
revised 50:19
Richman 1:8,8
3:11,12 27:5
34:6 38:10
41:24 54:17
87:12,16,18,25
88:16,23 89:11
89:16 90:4,9
90:15 93:13
95:14 102:1,13
102:25 103:17
103:23,24
20
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
104:3,14,20
105:3,16
106:17 107:3,6
107:20 108:6,8
116:10,11
137:23 138:6
138:15 140:2
151:14,15
154:12,25
Richman's 93:3
112:2 116:9
Rico 9:11,17,22
15:19 16:6,23
27:16,17,18
31:22 32:3,17
33:3,21 34:3
35:7 36:1
41:17 43:2
53:24 54:9,12
55:9,25 56:12
56:18 57:16
60:1 61:5 63:5
63:5,6,10 64:2
64:8,8 86:5,23
87:8 89:7 90:1
90:6,25 91:4
92:7 93:2,20
93:22 95:7
96:1,9,19,20
97:3 103:22
107:11 109:24
109:24 110:2
110:11 111:2,3
111:22 112:13
112:25 113:20
114:22 115:17
116:24,25
124:19 128:25
129:12 130:8
130:10,13,21
136:24 137:4,8
137:15,22
138:19 139:3
139:22 142:13
142:20 144:23
145:5,23
146:12,18
148:2,3 149:15
149:19,20
150:3,9 152:4
152:12,16,21
154:11,16
155:1,20 157:1
right 25:3 35:16
39:22 56:13
57:17 58:20
60:9 70:13
71:8 73:22
74:4 76:5,15
85:14,15 89:24
91:13 94:9
95:23 122:22
123:25 146:14
146:22 147:20
147:24 150:7
154:5 156:13
156:14
right-hand
140:15
rights 39:10
70:14 156:16
156:18
Ring 107:2
109:18 123:4,5
rip 67:20
roadblock
134:22
Robert 1:9,17
2:18 3:19 4:4
4:14,17 5:4,6
23:7,10,15,19
120:17,20
123:18 124:22
125:1 159:10
161:11 162:8
162:10,24
robocalling 68:8
rocks 67:11
Roeder 76:15
85:13 134:1,1
135:1
role 112:25
119:25 138:1
roof 75:23 82:8
room 40:19
84:13 117:13
RPR 161:24
162:22
rule 5:5 115:23
120:17,20
156:9
rules 77:5 121:4
162:18
run 64:21 66:25
112:11
running 79:6
109:15 119:19
119:20 130:25
133:23 144:19
S
S 3:4 4:9 5:1 6:1
162:25
S-o-d-h-i 117:11
S.E 2:20
sacred 156:16
safe 17:17,20
59:14
safely 53:7
saw 37:23 46:22
51:23 84:10
90:17 97:10
117:10 130:2
132:19 133:13
133:14
saying 20:4,24
38:9 39:4
64:21 68:19
72:17 77:23
80:3 91:4
102:9 107:8
110:12 114:18
115:21 117:5
121:16 130:13
147:7
says 48:16 74:2
81:5 89:16
98:13 148:18
scam 28:11
92:18 109:7
151:3
scanned 34:12
scans 26:14
scene 112:15
schedule 7:7
scheduling 75:1
75:5,16
scheme 67:22
68:10,10 94:6
108:25 111:9
111:14 112:7
115:3 119:21
119:22 123:8
140:16 141:19
142:17 151:2
156:19
schemes 69:17
69:21 134:19
schools 67:3
scope 95:10,20
98:17,20,23
99:7 100:9,10
100:16 104:11
107:19 108:8
126:14,18
Scott 3:15 14:3
74:2 76:16,17
88:16 116:7,13
122:20 157:3,4
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 85:11,11
86:13
serious 107:17
serve 133:6,11
135:9,11,13,14
served 17:6,8
20:8 36:22
102:4,17
117:19 120:21
125:5 132:25
133:1,19
135:21 150:21
serves 71:5
services 29:20
67:2,3
serving 67:1
100:15 130:25
135:8
set 30:16,18,21
60:3 110:3
117:12 147:13
settings 61:17
settle 15:5 61:1
62:1 74:16
75:22 77:23
84:23
settlement 59:22
60:2,5,17,25
63:21 74:22
75:14,20 77:7
77:8,15,16
82:24 85:9,21
86:8
settlements 45:9
46:6
settling 113:7
148:24
shake 111:9
sham 43:13,16
65:9 67:21
71:18
shams 69:12
share 107:20
149:11
sheet 160:1,24
Shepardize
115:11
short 85:19
short-change
62:18
shot 67:1 112:23
shots 45:19
show 21:20 22:6
51:3 73:7 88:4
108:24
showed 73:2
143:16
shut 68:7
sic 90:22
side 55:14
sign 137:25
162:14
SIGNATURE
160:23
signed 59:23
60:15 76:19
80:10 85:17
127:2 159:12
160:24
signing 162:13
Simon 38:25
simply 100:11
single 37:21
sit 9:7 20:9
22:11 26:3
61:21 72:6
84:19 115:11
127:20 135:18
sitting 24:8,8,9
157:8
situation 99:20
100:5 101:7
105:1 156:4
situations 154:7
six 19:14 47:10
53:8 58:11
132:19 135:25
skip 84:7
slander 37:21
38:16,18,20
39:5,7,8,9,11
39:21 118:14
slippery 156:10
slope 156:10
small 22:14
SMITH 3:5
society 67:11
68:2
Sodhi 117:11
154:12
solely 135:3
somebody 68:13
81:16 82:6
110:3 113:21
116:12 150:5
son 15:11 71:15
148:19
son's 109:17
sophisticated
18:12
sorry 12:22 16:8
16:20 23:24
40:20 123:14
sort 138:18
152:2 155:15
sought 106:16
sound 60:9
sounds 60:10
source 65:15
SOUTHERN
1:1 162:1
SOUZA 2:4,5
4:5 6:6 8:9
13:23 23:5,13
23:25 25:19,21
30:12 31:2,12
31:19 34:18,24
35:1 36:18,19
37:4,9,25 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
98:15 105:22
107:22 112:22
118:1,10,21
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
Spanish 6:14
speak 11:15
13:24 14:3
26:12 36:17
79:1 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
159:6,10,18
161:3
stated 8:22
21:23 33:25
41:12 68:15
74:25 75:7
86:17 94:1
95:7 120:8
124:7,11,16
statement 13:12
20:14 28:5
40:12 44:9,14
44:18 49:14,21
50:3,22 51:19
52:14,25 57:3
57:8,15 63:14
66:23 75:10,17
79:5 88:5
94:11 95:25
96:7,17 97:1
106:5 109:9
110:8,16,19
112:24 121:23
126:9 128:25
141:1 151:22
152:3,6,11,12
152:16 154:23
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20:17 29:6
40:4,6 52:16
54:21 63:21
64:17 78:2
94:5 95:17
96:12 116:18
130:2 140:21
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88:25 89:7,10
90:12 107:17
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steps 71:2
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stop 15:6 145:6
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146:1,9 162:13
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Stream 1:7 2:16
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7:12,19 8:4,14
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16:3 18:23
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Stream's 9:15
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studied 37:17
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subject 7:21 8:1
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36:12 42:9
53:20 59:18
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substance 12:3
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Suite 1:13 2:6,13
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summary 133:2
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Sunday 19:23
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Sunrise 2:13
Suntrust 3:7
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supplemented
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supported 9:10
suppose 117:20
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89:4 97:8,9
102:8 108:24
113:14,15
117:9 151:19
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surprise 94:24
surprised 90:19
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survivor 38:23
suspect 22:4
70:20 103:2
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suspicion 65:21
suspicious 66:9
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Sweetapple-5
4:21 73:10
Sweetapple-6
4:23 88:8
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5:4 120:16
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5:6 124:25
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23
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
28:5 49:13,21
50:6,22 52:13
52:16,25 66:23
109:9 159:11
system 67:17
68:12 69:4,5
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tasked 137:14,20
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155:9 156:24
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tell 6:11 10:13
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68:1 84:21
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68:4,4 106:9
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terabytes 108:20
term 41:21 97:6
terms 12:24
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18:4 28:24
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100:9 104:7
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106:18 151:20
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testify 8:20,24
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24:3 28:14
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104:13 110:5
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28:17,22,23,23
29:10 30:5
31:10 33:19
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35:11,16 36:11
37:11 38:22
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58:9,12,21
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69:3 70:2,11
70:11,17 71:19
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75:3,3 77:14
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81:1 82:12,22
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98:10,11 99:14
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114:12 115:16
115:18,24
116:5 117:13
119:16 121:2
122:19 123:7
126:11,12
134:20 135:25
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114:23 115:16
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41:22 42:25
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116:9 122:11
123:14 131:24
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thousands 18:15
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Thrasher 106:11
122:25 123:19
threat 99:23
150:16
threatened 56:4
threats 56:7
three 24:6 47:10
80:13 105:13
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threw 110:3
till 132:1 133:14
time 15:19 17:1
19:14 20:6
22:7 25:16
27:2 38:11,12
46:12,24 47:2
50:3 51:12
52:9,9,21 54:2
55:24 58:6
75:13,20 81:5
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84:15,22 88:19
98:19,21 99:9
99:19 100:24
101:18 102:11
103:21 104:7
105:6 108:24
117:15,15
130:24 131:11
135:15 136:14
139:9 141:24
142:11 153:5
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timeframe 46:3
74:3
timely 109:2
times 44:24
47:10 53:5
67:7 68:3
113:15 128:11
149:8
24
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
timing 147:1
Tobias 38:25
today 6:17,23
7:6,12,24 8:19
9:8 10:10
14:15 20:9
21:9,12 22:11
34:22 43:1
44:24 45:3
84:19 86:14
120:24 127:20
135:18 153:9
158:4
today's 14:19
told 7:3 13:20
14:4,12 51:23
55:24 56:10
62:9 70:5
72:10 75:23
79:3 83:9
87:12 103:15
103:18 106:25
123:5 129:11
130:1
tomorrow 89:17
top 38:11 73:21
topic 9:8,14,19
9:24 12:19,19
12:21,25 52:9
104:18
topics 6:25 7:6
7:22 8:20,25
9:3 10:11,15
11:20 12:1,3
12:16,17
tossed 112:13
totally 70:4,8
111:15 155:18
town 1:7 2:16
4:13 6:18 7:1,5
7:12,19 8:4,13
8:24 14:17
15:5,9,11 16:2
27:1 30:9,24
31:6,15 53:23
54:11 56:11
57:15 59:12
64:15,15,16
73:21 87:5,24
88:14 90:13
97:14,25 98:6
98:22,25 99:21
99:23 100:22
100:22 101:2
101:24 102:9
102:17 103:11
104:2,12
105:18,25
106:10 107:9
107:15,18
108:8,19 109:1
111:9 126:7
127:6,11,12
131:6 132:10
136:4 137:5
147:2 155:6
156:21,25
157:3,24 162:6
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Trail 6:14
training 9:6
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transcript 49:15
50:5 58:21
101:21 140:25
158:3 161:12
161:13 162:12
162:14,15,17
transmittal 29:4
Travel 73:25
traveled 74:6
treat 76:19
77:20 153:25
treated 50:7
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tremendous
45:23 154:17
trial 38:20 51:16
101:9 103:21
108:24 132:1
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trials 136:5,6
tried 11:10 21:1
38:21 39:5
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true 6:20 126:9
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truth 51:17
52:18,23
truthfully 120:1
120:1
trying 54:15
60:25 63:24
75:21 77:18
82:7 83:6
96:14 100:7
109:8,20 116:5
123:11 134:21
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turn 25:5 32:9
125:21 129:8
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Tweel 141:16
twice 53:8
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two 34:1 39:12
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109:7 113:15
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two-hour 74:3
type 31:11 44:11
44:14,19 46:15
67:10,15 68:10
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types 45:20 70:9
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ultimate 115:4
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ultimately 22:23
32:4 71:17
72:2 114:12
138:2 152:4
Um-hmm 26:25
unauthorized
80:5 103:25
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95:19 96:4
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155:15
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underlining
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40:3 89:19
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130:22 132:8
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118:19
understood 77:9
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undertake 97:16
undertaking
98:12
unfitness 39:16
unfortunately
70:25 153:14
156:8
UNITED 1:1
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University 115:7
unlicensed 78:21
80:25 102:7
104:18 105:6
unpleasantness
56:7
unprecedented
156:4
unusual 31:11
use 17:3 18:11
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91:3 94:18
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utter 65:8
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vaguely 82:21
valid 102:10
various 18:24
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verified 91:10
versed 154:19
version 37:3,10
37:15 158:7
versus 6:18
viability 113:19
116:25
vice 85:3 102:4
victims 94:7
video 20:15
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videotape 49:16
videotaping
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view 37:18 116:9
views 65:5
violated 41:17
95:7
violation 64:8
96:21 107:12
110:13 111:22
124:19
violations 41:16
25
Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
virtue 108:12
vis-a-vis 80:25
volume 147:3
voluminous 22:3
46:1
vote 97:24
voting 90:13
W
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walked 41:2
walking 84:13
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whistle 139:10
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wife 59:4,7 83:8
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William 122:25
willing 54:18
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yesterday 11:18
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Fort Lauderdale, Florida 954-755-6401
Daughters Reporting, Inc.
87:5 97:23
1400 3:7
15 7:23 15:20
16:10 87:5
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1500 1:13 2:6
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151 4:6
158 161:13
162:15
16 124:2
17 124:2
18 4:18 23:17,21
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1981 38:21
1982 89:14
1st 147:12
2
2 7:22 24:10,23
27:14
20 20:25 38:5
68:3 136:23
137:7 138:19
162:11
2000 16:13
2014 16:8 45:2
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60:8,18 61:8
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72:20 73:20,24
76:13 78:1
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81:18 82:17
83:11,24 84:18
85:11,11 86:13
104:8
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2016 1:14 37:1
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2017 159:12
161:21 162:9
22 4:19 23:17,21
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23rd 104:9 105:2
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954-755-6401
162:23