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Fri, 01 Apr 2016 08:22:44 -0700 (PDT) Microsoft Windows Live Mail 16.4.3528.331 Anonymous 0FD9571301363C0FD95860 Kelly Avery EX /o=GULFSTREAMTH/ou=first administrative group/cn=Recipients/cn=kavery kavery@gulf-stream.org Kelly Avery 10.01.2015 - In re Chandler - Condensed.pdf1001MRCHANDLER 1 of 44 sheets Page 1 to 4 of 135 01/26/2016 10:32:45 AM 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 UNITED STATED BANKRUPTCY COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION In re: JOEL EDWARDS CHANDLER and DEBORAH CHANDLER, Debtors. ] ] ] ] ] ] Case No.: 8:14-bk-142230-KRM Chapter 7 VIDEOTAPED DEPOSITION OF JOEL EDWARD CHANDLER DATE: October 1, 2015 TIME: 1:47 p.m. - 5 p.m. LOCATION: Johnson, Pope, Ruppel & Burns, LLP 403 East Madison Street Suite 400 Tampa, Florida 33602 PURSUANT TO: Notice, upon oral examination REPORTED BY: VANESSA MENDOZA, FPR Florida Professional Reporter Notary Public State of Florida at Large 2 APPEARANCES1 Appearin g Pro se: 2 M ARTIN O 'B OYLE C om merce Group, Inc.3 1280 West N ewport C enter Driv e D eerfield Beach, Flo rida 33442 4 (Mr. O ' Boyle videotaped depositio n.) 5 Counsel for Debtors: 6 FRANK PRIN CIPE, Esquire 2805 West B usch B oulevard, S uite 1007 Tam pa , Flo rida 33618 8 Counsel for CAFI: 9 D ANIEL DESOUZA, Esquire 101 NE 3rd A venue, S uite 1500 10 Fort Lauderdale, Flo rida 33301 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 IN DEX1 TESTIMONY O F JO EL EDWARD C HANDLER 2 EXAMIN ATIO N PAGE:3 B y Mr. O 'B oyle 5 4 5 6 C ertificate of O ath 120 7 C ertificate of Reporter 1218 S ig nature Page 122 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 EXHIBITS MARKED FOR ID ENTIFICATION:1 N O. D ESCRIPTIO N PAGE2 1 Com posite documents 72 3 2 Com posite documents 744 3 Com posite documents 1075 4 Com posite documents 107 6 5 Com posite documents 1077 6 Com posite documents 978 (Retained by M r. O 'B oyle) 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 01/26/2016 10:32:45 AM Page 5 to 8 of 135 2 of 44 sheets 5 THE COURT REPORTER: Do you swear or affirm the 1 testimony you give will be the truth, the whole 2 truth, and nothing but the truth?3 THE WITNESS: I do. 4 THE COURT REPORTER: Thank you.5 JOEL EDWARD CHANDLER,6 the witness herein, being duly sworn under oath, was 7 examined and testified as follows: 8 EXAMINATION9 BY MR. O'BOYLE:10 Mr. Chandler, my name is Martin O' Boyle, and I 11 Q. am here to take a 2004 examination of you in connection 12 with the bankruptcy that has been filed by you -- Joel 13 Edward Chandler, Senior, and Deborah D. Chandler in the 14 Middle District of Florida. And it is case number 15 8:14-bravo-kilo-14223-kilo-romeo-mike. 16 Could you state your name and address for the 17 record, please? 18 Joel Edward Chandler; 1355 Forest Park Street, 19 A. Lakeland, Florida 33803. 20 And, Mr. Chandler, how long have you lived 21 Q. there? 22 I don't know exactly. 23 A. Okay. Is it more than 50 years? 24 Q. You're asking me to speculate, and I'm under 25 A. 6 oath. 1 No, I'm asking you, is it more than 50 years? 2 Q. I said I don't know. I've already answered 3 A. your question. 4 Okay. So it may be more than 50 years? 5 Q. You asked me if I knew how long I have lived 6 A. there. 7 Uh-huh. 8 Q. I don't know exactly. 9 A. Right. I know that. And I asked you if it was 10 Q. more than 50 years and if maybe it is more than 50 years, 11 that's fine. 12 MR. PRINCIPE: You can answer. 13 BY MR. O'BOYLE:14 If it's not 50 years, just say "no." 15 Q. It's less than 50 years. 16 A. Very good. Is it less than 20 years? 17 Q. I don't know. 18 A. Okay. And I understand that house that you 19 Q. just described is in foreclosure; is that correct? 20 No. 21 A. It's not, okay. What is the status of it? 22 Q. I don't understand the question. 23 A. Okay. There's a house that you've lived in 24 Q. less than 50 years, correct?25 7 Yes. 1 A. Okay. And you said it's not in foreclosure, 2 Q. correct? 3 That's what I said, yes. 4 A. Yes. So is it -- if it's not in foreclosure is 5 Q. there a status to the house? Financially is there a 6 status? 7 I don't understand the question. 8 A. Okay. Do you have a mortgage on the house? 9 Q. Yes. 10 A. What's the status of the mortgage? 11 Q. MR. PRINCIPE: I think he's asking is it 12 current? Are you current on the payments? 13 Is that the question? 14 A. BY MR. O'BOYLE:15 Well, that's fine. Are you current on the 16 Q. payments? 17 I'm sorry, can you state the question? 18 A. Yeah. I said are you current on the payment? 19 Q. No, I'm not. 20 A. Okay. And why not? 21 Q. Because I haven't made the payments.22 A. Why not? 23 Q. In the beginning -- and I couldn't tell you 24 A. exactly what the dates are we're talking about -- I was 25 8 -- I had cash flow issues on a temporary fashion. And 1 when I contacted the mortgage holder who at the time -- I 2 can't remember who it was now because it's changed hands 3 so many times -- they basically told me that they 4 couldn't talk to me about making any arrangements unless 5 it was at least 90 days in arrears. 6 So I accommodated them, at which point my cash 7 flow issues were gone. And when I submitted payments 8 they sent them back and they refused to accept any more 9 payment. 10 So you did make an effort to pay the payments? 11 Q. Oh, yes. 12 A. Uh-huh. And they just refused to accept them? 13 Q. Yes. 14 A. And the reason again is? 15 Q. You'd have to ask them. 16 A. Okay. So they never gave you a reason? 17 Q. No. 18 A. Okay. They just sent you the money back? 19 Q. I don't recall the exact details, but they 20 A. would not accept payment. 21 Okay. Did you ever send the payments? 22 Q. Oh, yeah, I did. 23 A. Okay. So did they keep the money? 24 Q. The first round they didn't. Then we did a -- 25 A. 3 of 44 sheets Page 9 to 12 of 135 01/26/2016 10:32:45 AM 9 went through all the gyrations of a mortgage adjustment. 1 I submitted to them all the documents that they 2 requested, and I made I think it was 9 or 10 mortgage 3 payments and periodically during that time they would ask 4 to -- for updated information. I would provide to them 5 the exact same information I'd given them before. And 6 after, like I said, I think it was about 10 months or so 7 they said that they were not going to modify the loan. 8 That's the last time I made any payments to them, but 9 they kept all that money. 10 So it's been how long since you've made a 11 Q. payment? 12 I don't know. 13 A. More than a year? 14 Q. Yes. 15 A. More than two years? 16 Q. I don't know. 17 A. Okay. Do you know a Robert Sweetapple? 18 Q. I'm sorry? 19 A. Do you know a Robert Sweetapple? 20 Q. I do. 21 A. How? 22 Q. I have spoken to him on the phone a number of 23 A. times and met him once. 24 And where did you meet him? 25 Q. 10 In Lakeland. 1 A. I see. And how did you -- how did you get to 2 Q. speak to him? 3 I'm sorry, what does this have to do with the 4 A. bankruptcy? 5 We'll -- 6 Q. MR. PRINCIPE: Well, I object right now because 7 tell us how it relates to the bankruptcy, if you 8 know. 9 MR. O'BOYLE: I think it has to do or may have 10 to do with his financial condition. 11 If you want to ask me questions about my 12 A. finances, I'm an open book. I'll answer any questions, 13 but you know and I know that you are prohibited from 14 attempting to use a 2004 examination in order to gain an 15 advantage in an adversarial proceeding that is not 16 related to the bankruptcy. 17 BY MR. O'BOYLE:18 Well, thank you for sharing that with me. 19 Q. Would you now answer my question? 20 No, I won't. And if you'd like to get Judge 21 A. May on the phone, please do. 22 Okay. So you're refusing to answer that 23 Q. question? 24 I'm not going to answer any questions that are 25 A. 11 not related to the bankruptcy. If you want to ask me 1 anything you want to ask me about my finances, I will do 2 my dead level best -- 3 Okay. 4 Q. -- to answer your questions, but let me be 5 A. clear. Let's just get it out on the table right now. If 6 you're going to turn this into a circus where you want to 7 ask a bunch of questions about CAFI lawsuit or your 8 nonsensical claim or about Bob Sweetapple or about Joanne 9 O'Connor, if you want to ask me if they've given me any 10 money, I'll give you an honest answer; but beyond 11 finances, it's not relevant to this and we're not going 12 to talk about it. 13 Okay. 14 Q. So why don't we do this? 15 A. MR. PRINCIPE: Hang on. Hang on. Hang on. 16 Before we get going here, why don't you ask him how 17 it pertains to the bankruptcy instead of asking 37 18 questions and then maybe asking one question that 19 could relate to it so you can use the information? 20 Make sure you stick to what a 2004 exam is. That's 21 all we're asking. 22 MR. O'BOYLE: I think that's exactly what I'm 23 doing. 24 MR. PRINCIPE: Well, you asked him of Bob. He 25 12 told you. 1 MR. O'BOYLE: He told me he met him and spoke 2 with him a few times. 3 MR. PRINCIPE: Okay. Well, then ask another 4 question that relates to the bankruptcy or his 5 finances that relate to the bankruptcy. 6 MR. O'BOYLE: Well, I think having to do with 7 Sweetapple relates to the bankruptcy. That's what I 8 think, and I'm entitled to explore it. 9 MR. PRINCIPE: Ask the question. 10 MR. O'BOYLE: Okay. 11 BY MR. O'BOYLE:12 How did you come to meet Mr. Sweetapple? When 13 Q. I say "meet" -- you said you spoke to him I assume -- did 14 you speak to him before you met him? 15 Ask me a question about the bankruptcy, Marty. 16 A. MR. PRINCIPE: Ask the question. Just ask a 17 question first. 18 MR. O'BOYLE: I think I'm asking it. 19 MR. PRINCIPE: You said "did you speak to him 20 before?" I mean, just ask a question first and then 21 don't expand on something else. He can ask that if 22 it pertains to finances to your bankruptcy. 23 And I'm happy to answer any questions that 24 A. pertain to my finances. 25 01/26/2016 10:32:45 AM Page 13 to 16 of 135 4 of 44 sheets 13 BY MR. O'BOYLE:1 Unfortunately, Joel, you're not the sole 2 Q. arbiter here. 3 Right. So why don't we do this? Why don't we 4 A. stop and why don't you file a motion to compel and let's 5 see what Judge May has to say?6 Well, we're going to keep going. And if you 7 Q. want to leave the deposition, that will be something that 8 you will have decided to do. 9 Well, I'm not going to answer your question, so 10 A. ask something else. 11 You're not going to ask -- you're not going to 12 Q. answer that question? 13 No. 14 A. MR. O'BOYLE: Counsel? 15 MR. PRINCIPE: I think you can -- I think you 16 can answer that question. He just wants to know how 17 you know him as it pertains to the bankruptcy.18 THE DEPONENT: Look, Frank, it's as simple as 19 this. What Marty is attempting to do is to get at 20 the information that he threatened me over before. 21 When we were here before and he told me that he 22 wanted me to -- 23 MR. PRINCIPE: Let's not go into settlement 24 discussions. 25 14 THE DEPONENT: Hold on. It wasn't a settlement 1 discussion. That was a threat. 2 MR. PRINCIPE: Okay. 3 THE DEPONENT: That was Marty O'Boyle telling 4 me that if I didn't recant my sworn testimony that 5 he was going to unleash his massive finances and 6 stalk me to the ends of the earth. 7 You know, if we're going to have conversations 8 about the 2004 examination as they relate to my 9 bankruptcy, I'm more than happy to answer the 10 questions, but what he's attempting to do is to ask 11 the questions that he wants to work this deal with, 12 this whole -- 13 MR. PRINCIPE: Let's not get into the deal on 14 the record. 15 BY MR. O'BOYLE:16 You're refusing to answer the question? 17 Q. Marty, as I said before and I'm going to say it 18 A. for the last time. I will be more than happy to answer 19 to the best of my ability any questions that you or any 20 of my other creditors have regarding my finances. 21 Are you refusing to answer the question? 22 Q. Can you help me understand how that pertains to 23 A. my finances? 24 You have counsel. He -- if your counsel 25 Q. 15 advises you that it doesn't and advises you to not answer 1 the question, then I'll move on. 2 MR. PRINCIPE: I'd like to see where it goes. 3 Can we go off the record for a minute? Let me talk 4 to him outside. 5 (Recess from 2:03 p.m. to 2:08 p.m.) 6 MR. O'BOYLE: Back on. 7 BY MR. O'BOYLE:8 Mr. Chandler, there's a question that is 9 Q. pending, and I would ask once again that you kindly 10 answer. 11 What's the question? 12 A. (The preceding question was read by the court 13 reporter.) 14 BY MR. O'BOYLE:15 So there's the question. 16 Q. That was a compound question. Which one do you 17 A. want me to answer? 18 MR. O'BOYLE: Okay. Can you read the question 19 back again? 20 (The preceding question was read by the court 21 reporter.) 22 BY MR. O'BOYLE:23 Let's stop right there. How did you come to 24 Q. meet Mr. Sweetapple? 25 16 Can I ask you to rephrase the question? 1 A. No. 2 Q. I don't understand the question. 3 A. Okay. Did you meet Mr. Sweetapple? 4 Q. I did. 5 A. How did you come to meet him? 6 Q. You're asking me the same question again. I 7 A. don't understand the question. You're not willing to 8 rephrase. 9 Were you in an airplane and that's where you 10 Q. met him? 11 No. I drove. Is that how you -- how did I -- 12 A. how did I -- transportation-wise how did I go to meet 13 him? I drove. 14 Well, how did -- how did you come to meet him? 15 Q. As an example, if you had told me you met President Obama 16 I would say to you "how did you come to meet President 17 Obama?" And I'm asking the same question about 18 Mr. Sweetapple, and I don't think it's that difficult. 19 MR. PRINCIPE: Objection; I don't think it 20 pertains to a 2004 exam. 21 I'm just asking that you rephrase the question. 22 A. I don't know what you mean. That's why I said -- how did 23 I come to meet him? I drove my car is the first thing 24 that popped into my head, but frankly, I thought that 25 5 of 44 sheets Page 17 to 20 of 135 01/26/2016 10:32:45 AM 17 sounded like a smartass answer until you said "well, did 1 you take a plane?" I came to meet him in my car. 2 BY MR. O'BOYLE:3 Okay. And when you drive down the turnpike -- 4 Q. as an example, you drive down the turnpike a lot, 5 correct?6 I do not. 7 A. Okay. Where do you -- what's your main road 8 Q. that you drive on? 9 MR. PRINCIPE: What is -- objection; that has 10 nothing to do with his bankruptcy, where he drives. 11 BY MR. O'BOYLE:12 You may answer. 13 Q. I rarely drive. 14 A. Okay. But when you do drive you don't just 15 Q. meet people along the road when you're driving down the 16 turnpike 95, 60, 75? 17 When I was traveling -- actually, when I travel 18 A. the roads I meet people frequently. 19 Okay. And did you meet Mr. Sweetapple when you 20 Q. were driving the roads? 21 No. I drove to meet him. 22 A. Okay. And how did -- what -- how did you come 23 Q. to decide to drive to meet Mr. Sweetapple? 24 He invited me to meet him. 25 A. 18 Okay. And did he invite you for dinner? What 1 Q. did he invite you for? What purpose? 2 To -- he wanted to ask me some questions. 3 A. And in what connection? How to make stew? 4 Q. What did he want to know? 5 MR. PRINCIPE: Objection. Well, how is this 6 relevant to the bankruptcy? You're not there yet. 7 You're asking the questions before you get to a 8 bankruptcy question. 9 MR. O'BOYLE: I understand. 10 MR. PRINCIPE: I'm asking. 11 MR. O'BOYLE: I understand. 12 MR. PRINCIPE: Or we're going to have to call 13 the judge. 14 MR. O'BOYLE: Well, he could refuse to answer. 15 That'll be all right with me. 16 MR. PRINCIPE: It's your call. I don't see it 17 pertains to the bankruptcy. 18 THE DEPONENT: I don't either. 19 He asked me a lot of questions. 20 A. BY MR. O'BOYLE:21 Why did he ask you questions? 22 Q. I suppose he was looking for answers. 23 A. And the type questions he asked you, were they 24 Q. in connection with housing prices, food? What were they 25 19 in connection with? Tires? What were they in connection 1 with? 2 He asked me many questions. I couldn't tell 3 A. you exactly -- what all the questions -- it was many, 4 many months ago. 5 Uh-huh. 6 Q. It was over the course of several hours, as I 7 A. recall. I -- and I don't know. The topics were various 8 and sundry. 9 But he may have asked you about tires? 10 Q. I don't recall him asking me about tires. 11 A. Well, you just said you didn't know. 12 Q. Is there a question? 13 A. Uh-huh. 14 Q. What's the question? 15 A. Did he -- did you just say that you didn't know 16 Q. about tires? 17 Can you read back what I said? 18 A. THE COURT REPORTER: Which answer? An answer? 19 Your answer? 20 THE DEPONENT: Whatever it is he's asking me I 21 said.22 MR. O'BOYLE: This is the one where I said 23 tires, I think food. I don't remember exactly.24 (The preceding question was read by the court 25 20 reporter.) 1 MR. O'BOYLE: And his response? 2 (The preceding question was read by the court 3 reporter.) 4 BY MR. O'BOYLE:5 Okay. 6 Q. So, no, according to the transcriptionist, I 7 A. didn't say I don't know. That was your last question. 8 You have no idea why he summoned you down to 9 Q. southern Florida; is that correct? 10 I have no idea what you're talking about. 11 A. Okay. Did he summon you to southern Florida?12 Q. No, he did not. 13 A. I thought you said that he had you come down. 14 Q. I don't believe I said that. 15 A. THE DEPONENT: Can you -- 16 MR. O'BOYLE: No, you don't have to. 17 Just strike that.18 BY MR. O'BOYLE:19 What possessed you to leave your home in 20 Q. Lakeland and meet Mr. -- well, first of all, where did 21 you meet Mr. Sweetapple? 22 I've already answered this question. 23 A. Okay. Well, can you answer it again? 24 Q. I've already answered your question. Asked and 25 A. 01/26/2016 10:32:45 AM Page 21 to 24 of 135 6 of 44 sheets 21 answered. Move along. 1 MR. O'BOYLE: Counsel? 2 MR. PRINCIPE: Answer it again. 3 I said Lakeland. 4 A. BY MR. O'BOYLE:5 Okay. You met -- you met him in Lakeland? 6 Q. Yes. 7 A. Okay. What possessed him to come to Lakeland? 8 Q. You'd have to ask him. 9 A. What induced him to come to Lakeland?10 Q. You'd have to ask him.11 A. Did you have any conversations with him before 12 Q. he came to Lakeland? 13 I did. 14 A. And what were the conversations? What was the 15 Q. thrust of the conversations? 16 About meeting in Lakeland. 17 A. And that's all? You had multiple 18 Q. conversations. What you're telling me -- and if I'm 19 incorrect please correct me -- what you're telling me is 20 the conversations that you had before his trip to 21 Lakeland, all you spoke about was him coming to Lakeland; 22 that's it, right?23 I'm sorry. If you're going to testify you need 24 A. to be under oath. 25 22 It's a question. 1 Q. That wasn't a question. 2 A. It was. I said "right?" Question mark. 3 Q. I'm confused. 4 A. Okay. Mr. Sweetapple came to Lakeland, 5 Q. correct?6 Yes. 7 A. Okay. And he came to Lakeland to see you, 8 Q. correct?9 I don't know what all the reasons were for him 10 A. coming to Lakeland. We met in Lakeland. 11 So he came to see you. I didn't say limited to 12 Q. coming to see you. I said he came to see you. 13 Again, you're asking me about his motivations 14 A. for traveling presumably. I can't tell you. I can tell 15 you I met him in Lakeland. 16 Okay. And when you met him in Lakeland what 17 Q. happened? 18 We talked. 19 A. And where did you meet? 20 Q. MR. PRINCIPE: Objection; I still don't see 21 this line of questioning going towards a 2004 exam. 22 MR. O'BOYLE: You will. 23 MR. PRINCIPE: I want to know how it pertains 24 to a 2004 exam. I don't want you to ask 37 25 23 questions, and then we decide that it doesn't 1 pertain to a 2004 exam. It seems to me that you're 2 fishing in response to some sort of lawsuit that's 3 pending out there against you and some other 4 entities. That's not what a 2004 exam is. 5 MR. O'BOYLE: I'm aware. 6 MR. PRINCIPE: And we're going to -- if we have 7 to adjourn we will. Do you have any other questions 8 that you know pertains to the bankruptcy? 9 MR. O'BOYLE: Well, I believe that the 10 questions I've been asking pertain to the 11 bankruptcy; his schedules, his -- 12 MR. PRINCIPE: How does it pertain to the 13 schedules? 14 MR. O'BOYLE: Well, his -- his interaction with 15 Sweet -- Sweetapple ties directly into CAFI, which 16 is in his schedules. 17 MR. PRINCIPE: CAFI is in the schedules because 18 they're a disputed creditor in the case. He's under 19 oath to list all claims that could possibly be out 20 there against him. And that's why they're listed 21 and you know that. 22 MR. O'BOYLE: I understand, and I gave you my 23 answer. And if you want to instruct him not to 24 answer I understand. 25 24 MR. PRINCIPE: What do you think? 1 What was the question again? 2 A. (The preceding question was read by the court 3 reporter.) 4 I don't understand what you mean by where did 5 A. we meet. 6 BY MR. O'BOYLE:7 Okay. 8 Q. MR. PRINCIPE: Objection; how does that pertain 9 to the bankruptcy because they met somewhere? Maybe 10 they met in a tree, but I don't get that pertains to 11 his bankruptcy and his financial condition; where 12 they met. Now, there may be another question out 13 there, but that's not one of them. 14 MR. O'BOYLE: Yeah. Well, I'm getting -- I'm 15 getting to where I want to go, but I think I need 16 this foundation information, and I don't think that 17 there is any reason in the world that I shouldn't 18 get it. 19 MR. PRINCIPE: Well, the objection's on the 20 record. 21 MR. O'BOYLE: Right. 22 BY MR. O'BOYLE:23 There's a question pending. 24 Q. MR. PRINCIPE: It's not relevant. Where did 25 7 of 44 sheets Page 25 to 28 of 135 01/26/2016 10:32:45 AM 25 you meet?1 THE DEPONENT: And I said I don't understand 2 the question. 3 BY MR. O'BOYLE:4 You don't understand where you met means? 5 Q. Where did you meet? You don't understand what that 6 means? 7 I told you we met in Lakeland. 8 A. I understand. You met every corner in 9 Q. Lakeland? Every store in Lakeland? Every apartment in 10 Lakeland? 11 MR. PRINCIPE: Objection to the question; 12 sarcasm. 13 BY MR. O'BOYLE:14 You met at all those places? 15 Q. That was a compound question. I don't know how 16 A. to answer that last question you just asked me.17 Okay. Did you meet on the corner of any 18 Q. streets in Lakeland? 19 No. 20 A. Okay. Did you meet at the YMCA? 21 Q. No. 22 A. Did you meet at any department stores? 23 Q. MR. PRINCIPE: Objection to the line of 24 questioning; it does not relate to the bankruptcy. 25 26 You can answer.1 BY MR. O'BOYLE:2 You may answer. 3 Q. No.4 A. No. Where did you meet? 5 Q. Are you asking me for an address? 6 A. No. 7 Q. I don't understand what you're asking me for. 8 A. I am asking you to instead of -- 9 Did you meet at a lawyer's office? 10 Q. No. 11 A. Did you meet at a court reporter's office? 12 Q. Yes. 13 A. Okay. So now I think I'm understanding. 14 Q. Mr. Sweetapple called you and all he said -- 15 MR. PRINCIPE: Please ask a question. 16 MR. O'BOYLE: Pardon? 17 MR. PRINCIPE: Please ask a question. 18 MR. O'BOYLE: I'm asking a question. 19 BY MR. O'BOYLE:20 Mr. Sweetapple called you and all he said was 21 Q. "I'm coming to Lakeland." And when he got up here you 22 were surprised that he went to a court reporter's office; 23 is that correct? 24 That was a compound question. I don't know how 25 A. 27 to answer it. 1 Okay. How did you end up -- did you know you 2 Q. were going to a court reporter's office before you got to 3 the court reporter's office? 4 In reference to my meeting with Bob Sweetapple? 5 A. Yes. 6 Q. Yes. 7 A. You knew? 8 Q. Yes. 9 A. How did you know? 10 Q. MR. PRINCIPE: Objection. How does that 11 pertain to this bankruptcy? How does it pertain to 12 CAFI? Well, how does it pertain to CAFI in the suit 13 against him? 14 Well, here's the other question I have. If it 15 A. relates to the CAFI lawsuit are you representing CAFI? 16 Why are you -- why do you have any standing to ask me any 17 questions about my debt with -- the alleged debt with 18 CAFI. I don't understand. 19 BY MR. O'BOYLE:20 When you take my deposition I'll answer that 21 Q. question, but meanwhile this is my deposition. 22 Go ahead. 23 A. Okay. Well, I think I have a question on the 24 Q. table here. 25 28 MR. PRINCIPE: And we've objected. 1 And I said it was a compound question. 2 A. BY MR. O'BOYLE:3 Then I asked another question after that. 4 Q. MR. PRINCIPE: What was the last question he 5 asked, please? 6 (The preceding question was read by the court 7 reporter.) 8 I don't recall. 9 A. BY MR. O'BOYLE:10 You don't recall how you knew? 11 Q. Asked and answered. 12 A. No. I'm asking you how did you know? 13 Q. I said I didn't recall. 14 A. MR. PRINCIPE: Then he did answer the question. 15 And then you asked me again "you didn't 16 A. recall?" No, you can't keep asking me the same questions 17 over and over again. 18 Mr. Chandler, this is my deposition, sir. I'm 19 Q. not going to be lectured by you, nor am I going to be 20 told what to do by you. If you want to leave, that's up 21 to you. You're going to answer the questions that I'm 22 entitled to ask. If you don't understand the question, I 23 will be glad to take as much time as necessary to try to 24 make it so you do understand it so that you could easily 25 01/26/2016 10:32:45 AM Page 29 to 32 of 135 8 of 44 sheets 29 answer it. That's my goal. 1 Okay. Go ahead. If you'll do that I'm more 2 A. than happy to participate. 3 Okay. Mr. Sweetapple came and he took a sworn 4 Q. statement, correct, from you? 5 Yes. 6 A. Okay. If I would have come up would you have 7 Q. given me a sworn statement? 8 I don't know. 9 A. Okay. 10 Q. I'm giving you -- I'm giving you -- I'm 11 A. answering your questions under oath now. 12 This is a 2004 examination, as you pointed out. 13 Q. If I come up next week and ask you to meet me at a court 14 reporter's office so that we could ask broader questions 15 beyond the 2004 examination, similar to what you did with 16 Mr. Sweetapple, you'd agree to that or not? 17 I don't know. You've never asked me to. 18 A. I'm asking you now. 19 Q. MR. PRINCIPE: That's not a -- that's not a 20 proper question for a deposition. Objection. 21 BY MR. O'BOYLE:22 You may answer. 23 Q. I don't know. 24 A. You don't know if you'd allow it? 25 Q. 30 I don't know. 1 A. So you might and then again you might not, 2 Q. correct?3 Okay. Asked and answered twice. 4 A. Okay. Do you -- in your United States 5 Q. bankruptcy schedule -- this is for the current 6 bankruptcy -- before I get into that, you had a previous 7 bankruptcy, didn't you? 8 Yes. 9 A. And -- excuse me -- what happened to that? 10 Q. I dismissed it. 11 A. You dismissed it? 12 Q. I believe that we -- my wife and I dismissed it 13 A. with the help of our attorneys, as I recall. 14 Okay. Why would you dismiss it if you'd filed 15 Q. it? 16 It was filed as -- as I recall, a Chapter 13. 17 A. A Chapter 13, you say? 18 Q. As I recall. 19 A. Okay. Would you kindly answer my question? 20 Q. Yeah. We filed a Chapter 13, and then when I 21 A. left my job with Citizens Awareness Foundation, it was no 22 longer possible for us to meet the agreed-upon payment 23 structure with the court, so we dismissed the case. 24 And did you dismiss it immediately upon your 25 Q. 31 leaving Citizens? 1 I don't know. 2 A. You don't know? 3 Q. I don't recall. 4 A. Okay. In your schedules you say "potential 5 Q. claim against Marty O'Boyle for slander." What is that 6 claim and where did it emanate from? 7 I'm sorry, that was a two-part question. One 8 A. at a time. 9 Sure. What is that claim? 10 Q. For slander. 11 A. And what is the slander? 12 Q. False statements that I believe you made about 13 A. me. 14 And what false statements do you believe that I 15 Q. made? 16 I'd have to go back and give you some thought. 17 A. I can't tell you off the top of my head. 18 So you don't know of any as you sit here? 19 Q. I'd have to give it some thought. There were 20 A. so many. 21 Can you answer my question? 22 Q. I just did. 23 A. No, you didn't. 24 Q. I'm sorry you don't like the answers that I'm 25 A. 32 giving you, but I answered the question. 1 No, you didn't. 2 Q. Move along. 3 A. Don't tell me what to do, Mr. Chandler. 4 Q. MR. PRINCIPE: Don't say that. 5 BY MR. O'BOYLE:6 Don't do it. 7 Q. MR. O'BOYLE: Would you read my question back, 8 young lady? 9 THE COURT REPORTER: Sure. 10 (The preceding question was read by the court 11 reporter.) 12 BY MR. O'BOYLE:13 I don't think you answered my question. 14 Q. I've answered your question. 15 A. MR. O'BOYLE: Okay. Can you read my question 16 back one more time, just my question? 17 (The preceding question was read by the court 18 reporter.) 19 MR. O'BOYLE: I think the one after that. What 20 was his answer there?21 (The preceding question was read by the court 22 reporter.) 23 BY MR. O'BOYLE:24 Can you tell me any false statements that I 25 Q. 9 of 44 sheets Page 33 to 36 of 135 01/26/2016 10:32:45 AM 33 made about you. 1 Yeah. Your nonsensical claim that I had stole 2 A. money from CAFI. 3 And I made that statement directly to you or to 4 Q. who? 5 No. I don't think you made that statement 6 A. directly to me. 7 Who did I make it to? 8 Q. I don't know off the top of my head. 9 A. How do you know that I made it? 10 Q. Well, let's see. I saw a videotaped deposition 11 A. that you participated in where you made that statement 12 under oath and on the record. 13 And how would you have come to see a videotaped 14 Q. deposition? 15 YouTube. 16 A. YouTube? 17 Q. I think it was YouTube. It was online 18 A. someplace. 19 I see. Okay. And is that the only slander 20 Q. that you assert? 21 No. I need to go back and consult my notes. 22 A. I'm confident there are more, but without going back and 23 looking at my notes it would be difficult for me to -- 24 How could you say you're confident that there's 25 Q. 34 more? If you can't remember them how could you say 1 you're confident there's more? 2 I'm confident that there are more. I don't 3 A. remember all of them off the top of my head. I would 4 want to go back and look at my notes. 5 And if I was asking for all of them, I might 6 Q. understand that, but I'm not. What other ones are there? 7 Give me one. Give me three. Give me five. Give me 50; 8 whatever you -- whatever you can remember. 9 I've answered your question. 10 A. So you can't remember any; is that correct? 11 Q. MR. PRINCIPE: He gave you one. 12 MR. O'BOYLE: Besides the one. 13 I've already mentioned one. I've already said 14 A. that I would need to give it more thought. I've also 15 said that I would need to consult my notes. I've said 16 that I can't recall each of them; there are so many of 17 them. So I think I've answered that question over and 18 over and over again. 19 BY MR. O'BOYLE:20 And I believe that's what you think, but I 21 Q. don't -- as far as I'm concerned, your answer is 22 unsatisfactory. What I want to know is, you have notes 23 showing a plethora of slanders. There's so many of them 24 you can't remember. Not one? 25 35 I've already mentioned one in particular. 1 A. No. No. No. Not a one in addition to -- 2 Q. Well, that would be more than one. 3 A. One in addition to. Well, I'm not going to 4 Q. argue with you about more than one or whatever. I'm 5 asking, are there any others besides the one that you 6 told me about, which was in a litigation deposition? 7 I'm confident there are. I would need to 8 A. consult my notes to refresh my memory about the 9 particulars of them, and since I'm under oath I want to 10 be precise in my answers. 11 Okay. Do you have any other claims against me? 12 Q. None that come to mind. 13 A. Is that a yes or is that a no? 14 Q. It's not a question that begs a yes-or-no 15 A. answer. None that come to mind. I don't know that there 16 are. I'm not prepared to say that there aren't any. 17 There may be -- there may be claims that have not yet 18 presented themselves. 19 Well, let me ask you this then. 20 Q. MR. PRINCIPE: Hang on. Just for 21 clarification, can you put a time frame again on it? 22 MR. O'BOYLE: On what? 23 MR. PRINCIPE: On the question you're asking; 24 is there a claim out there because -- 25 36 MR. O'BOYLE: As of today. 1 MR. PRINCIPE: As of today. Do you know of 2 any -- 3 None that I -- none that I can recall. None 4 A. that I'm immediately aware of. 5 BY MR. O'BOYLE:6 Okay. Now, Mr. Chandler, I am going to read to 7 Q. you on page 25 of 47 of your filing the declaration 8 concerning debtors schedules. 9 MR. PRINCIPE: Go ahead. 10 BY MR. O'BOYLE:11 "I declare under penalty of perjury that I have 12 Q. read the foregoing summary and schedules consisting of 24 13 sheets and that they are true and correct to the best of 14 my knowledge, information, and belief." Where are the 15 other claims that you have or did you perjure yourself? 16 I did not perjure myself. 17 A. Well, shouldn't they be on the bankruptcy? 18 Q. My answer was none that I'm aware of; none that 19 A. immediately present themselves to me. Off the top of my 20 head I can't think of any. That's not to say -- let me 21 be clear for the record -- that's not to say as I've 22 already indicated there may be unknown causes of action, 23 things that I don't know about that's entirely possible 24 given your lack of character and your willingness to bend 25 01/26/2016 10:32:45 AM Page 37 to 40 of 135 10 of 44 sheets 37 the truth. To the best of my knowledge, which is what 1 this says, this is all that's there. There's nothing 2 else that I'm aware of. That's not to say that there 3 aren't others -- 4 Okay. 5 Q. -- that I may not be aware of. 6 A. MR. PRINCIPE: Let me remind you, though, this 7 is as of that date of filing, so you're asking about 8 through today. 9 MR. O'BOYLE: I understand. 10 MR. PRINCIPE: So there may be, as we call it, 11 a post-petition claim. I don't know. He's 12 testifying that he doesn't know about it. 13 MR. O'BOYLE: And I -- and I understand. But 14 the day that he filled this out -- 15 BY MR. O'BOYLE:16 -- this was the only potential claim that you 17 Q. had against me, correct?18 That I was aware of, yes. 19 A. Okay. Well, of course that you're aware of. 20 Q. What I said, it's entirely possible that there 21 A. could be all manner of unknown claims. I have no idea. 22 But you know of none? 23 Q. That's what I've said. I've already said that. 24 A. Okay. No. You said before you had a list of 25 Q. 38 them on a piece of paper. 1 MR. PRINCIPE: No, that's not -- 2 No, I didn't. 3 A. MR. PRINCIPE: That all pertains to the slander 4 claim, which is listed on the schedules. 5 BY MR. O'BOYLE:6 Okay. 7 Q. You asked me for an example of slander. I gave 8 A. you one example. You asked me for all the other ones. I 9 don't know. I got to look at my notes. I have no idea. 10 Okay. When -- how many times have you seen me 11 Q. since 12/17/14? 12 MR. PRINCIPE: That's since you filed the 13 Chapter 7. 14 I think this is our second meeting, as I 15 A. recall. 16 BY MR. O'BOYLE:17 Okay. And our first one was across the hall 18 Q. here; am I correct?19 I think we met here, but -- 20 A. Yeah. Here and then we went across the hall, 21 Q. if I recall. 22 Yeah, in the room where you threatened me, yes. 23 A. You threatened me that if I didn't recant my sworn 24 testimony that you were going to do all kinds of bad 25 39 things to me and my family. 1 Your attorney was there? 2 Q. He was, as was my wife. 3 A. If you want to assert that, you make your 4 Q. assertions. 5 I already have. Yes, you threatened me. You 6 A. threatened me that if I didn't recant my sworn testimony 7 that you're very wealthy and you were going to spend 8 whatever it takes to wreck my life. Yes, I am asserting 9 that. 10 Do you have a problem with the truth? You're 11 Q. not a very honest man, are you? 12 I think I am a truthful person. 13 A. Well, what you just said was not truthful at 14 Q. all; not even close to being truthful. 15 MR. PRINCIPE: Is that a question? 16 MR. O'BOYLE: Yes. 17 How is that a question? 18 A. MR. PRINCIPE: Phrase it in a question. 19 MR. O'BOYLE: I just did. 20 BY MR. O'BOYLE:21 Is it? 22 Q. You did threaten me. You threatened me. 23 A. When did I threaten you? 24 Q. I'm sorry? 25 A. 40 When did I threaten you? 1 Q. I've already answered this question. Across 2 A. the hall you threatened me. One of the first things out 3 of your mouth was that if I didn't recant my sworn 4 testimony, that you were very wealthy and you were going 5 to spend all kinds of money to just keep coming after me, 6 if I didn't recant my sworn testimony. 7 Mr. Chandler, have you ever been arrested? 8 Q. I have. 9 A. For what? 10 Q. For solicitation of prostitution in 1990, 11 A. December. 12 Now, would you say that as a result you have 13 Q. good character? 14 I think like all people I'm flawed. 15 A. Well, that's true. I agree with you, but can 16 Q. you answer my question? 17 I did just answer the question. 18 A. No. You said -- I said, do you think you have 19 Q. good character and you said like all people you're 20 flawed. My question was, do you think you have good 21 character? 22 I think like all people I have character flaws. 23 A. Okay. Does that fit into the good character or 24 Q. the bad character? 25 11 of 44 sheets Page 41 to 44 of 135 01/26/2016 10:32:45 AM 41 I believe in the duality in man. I also 1 A. believe in the total depravity of man. I believe that 2 all men are capable of the most heinous acts, and even 3 the most heinous men are capable of extraordinary acts of 4 generosity and kindness. 5 I think we are made of the same stuff that 6 Mother Teresa is made of and the same stuff that Charles 7 Manson is made of. So I think we all have the ability to 8 do good things and bad things, and I think that as far as 9 my character is concerned, I'm capable of horrible 10 things, and I'm capable of extraordinarily good things, 11 just like you and just like everyone else. 12 How do you know you're capable of horrible 13 Q. things; because of what you did to my son? 14 MR. PRINCIPE: How's that -- objection; how 15 does that pertain to the bankruptcy? Objection. 16 Strongly objecting. 17 I don't know what you're referring to when you 18 A. say what I did to your son. 19 MR. PRINCIPE: Don't answer. Let him ask 20 another question. 21 BY MR. O'BOYLE:22 So your potential claim against me for slander 23 Q. is limited to a litigation deposition on you said you 24 think it's YouTube and across the hall that I said 25 42 something about I have a lot of money or something? 1 No. 2 A. No, you didn't say that? 3 Q. No. 4 A. What did you say? 5 Q. At what point in this conversation? 6 A. Well, let's start -- 7 Q. MR. PRINCIPE: He's asking if there's any more 8 instances again of slander other than the one -- 9 I think that there probably are. And just so 10 A. we're clear, in filling out the paperwork for the 11 bankruptcy -- I'm not an attorney. I don't purport to be 12 an attorney. I'm not trying to draw any legal 13 conclusions. The question that was presented to me in 14 the filing paperwork and by the trustee is, "Are you 15 aware of any -- is there anybody we can sue on behalf of 16 the -- of the estate of the bankruptcy?" And my response 17 is, "This is the only thing that I can think of; it's the 18 only one I know of. I'm not in a position to draw any 19 legal conclusions about that." 20 I'm trying to be as helpful to the bankruptcy 21 trustee as I possibly can by disclosing everything that 22 she has asked for and everything that the court has asked 23 for.24 BY MR. O'BOYLE: 25 43 Okay. Besides slander do you have any other 1 Q. claims against me? 2 I've already answered this question. 3 A. Okay. 4 Q. MR. PRINCIPE: Objection; he has answered this. 5 BY MR. O'BOYLE:6 Okay. Except for the claims -- the claim for 7 Q. slander, line 21 on page -- 8 MR. PRINCIPE: What page are you on?9 MR. O'BOYLE: 7. 10 BY MR. O'BOYLE:11 -- do you have any claims against anyone in 12 Q. Palm Beach or Broward County? 13 During what time frame? 14 A. Now. 15 Q. Not that I'm aware of.16 A. Okay. 17 Q. None that come to mind. 18 A. Huh? 19 Q. None that come to mind.20 A. All right. Okay. So there may be claims; is 21 Q. that correct? 22 I don't know. 23 A. You don't know if there may be? There's maybe 24 Q. and then there's maybe not. And I don't know of anything 25 44 else besides those two. And you don't know; is that 1 correct? 2 I've already answered the question. 3 A. Okay. I'll accept that answer. How did you 4 Q. get here today? 5 I drove. 6 A. What did you drive? 7 Q. A car. 8 A. What kind of car? 9 Q. Daewoo. 10 A. And what year is the Daewoo? 11 Q. I have no idea. 12 A. Okay. Who owns the Daewoo; whatever it's 13 Q. called? 14 One of my sons does. 15 A. I see. And what son would that be? 16 Q. Samuel. 17 A. Samuel. And you have a potential counterclaim 18 Q. against Citizens Awareness Foundation, Inc., for 19 vexatious litigation, am I correct, at least that's on 20 your schedule? I shouldn't say you have. 21 Yeah. I think -- I think the way I would 22 A. characterize it is that the estate or the bankruptcy 23 does. I don't think that I personally do any longer 24 because I filed for bankruptcy. 25 01/26/2016 10:32:45 AM Page 45 to 48 of 135 12 of 44 sheets 45 But when you filled this out -- 1 Q. Yeah. 2 A. What is it about? You filled it out under 3 Q. oath? 4 Yeah. The nonsensical lawsuit that Citizens 5 A. Awareness Foundation has filed against me. 6 And it's nonsensical based on? 7 Q. This has nothing to do with the bankruptcy. 8 A. Again, my concern about answering-- 9 MR. PRINCIPE: That's -- let me interject. I 10 think that that does pertain to the bankruptcy, that 11 lawsuit, because you've listed it and you've listed 12 it -- 13 THE DEPONENT: The bankruptcy does -- I 14 agree -- but since it's pending litigation outside 15 of the bankruptcy, the 2004 exam is not supposed to 16 be used as a means of gaining an adversarial 17 advantage, which -- 18 MR. PRINCIPE: I get that. Ask your question 19 again. Ask your question again.20 (The preceding question was read by the court 21 reporter.) 22 MR. PRINCIPE: The one before that.23 (The preceding question was read by the court 24 reporter.) 25 46 THE DEPONENT: The last question was why was a 1 nonsensical -- it's a meritless lawsuit. There's no 2 merit to it. 3 BY MR. O'BOYLE:4 And who divined that there was no merit to it? 5 Q. I have reviewed it, and I have sought legal 6 A. counsel and the conclusion was unanimous that it is 7 without merit. 8 What legal counsel did you consult? 9 Q. I'm not under obligation to answer any 10 A. questions about communications with me and my legal 11 counsel or even who my legal counsel may be. 12 MR. O'BOYLE: Counsel? 13 MR. PRINCIPE: He can ask you who you 14 contacted, but he can't ask you the discussions. 15 A number of attorneys. 16 A. BY MR. O'BOYLE:17 What -- can you -- I'd like the names of the -- 18 Q. of all of them. 19 I couldn't name all of them. I'd have to go 20 A. back and look at my notes. 21 Of course. I recognize that you have to look 22 Q. at your notes to answer most questions, but you don't 23 remember any of them? 24 You asked -- you said you wanted me to name all 25 A. 47 of them. 1 I just said you don't remember any of them? 2 Q. I do remember some of them. 3 A. Can I have their names, please? 4 Q. Greg Thomas; Ana Clara Anderson. 5 A. I'm sorry; Ana? 6 Q. Ana Clara Anderson. And I'd have to -- there 7 A. were others. 8 Okay. But that's all you know about? 9 Q. MR. PRINCIPE: That's not what he answered. 10 MR. O'BOYLE: I just said "that's all you know 11 about today."12 MR. PRINCIPE: Okay. That's it.13 BY MR. O'BOYLE:14 Correct? 15 Q. I wouldn't say that's all I know about them. 16 A. I'm saying I would need to refresh my memory by looking 17 at my notes. 18 Okay. This is all you recall today? 19 Q. With certainty, yes. 20 A. Okay. Now, was Sherry Hopkins one of the 21 Q. lawyers you consulted? 22 I don't believe so. 23 A. Do you know Sherry Hopkins? 24 Q. That name's familiar to me. 25 A. 48 Can you place her? 1 Q. If I'm not mistaken, she -- there's a woman 2 A. named Sherry Hopkins who represented the City of 3 St. Cloud. 4 Go ahead. 5 Q. MR. PRINCIPE: I think he answered your 6 question. 7 MR. O'BOYLE: Okay. 8 BY MR. O'BOYLE:9 Now, Mr. Chandler -- 10 Q. Hold on a minute. 11 A. MR. PRINCIPE: Go off the record for a second. 12 (Recess from 2:48 p.m. to 3 p.m.)13 THE COURT REPORTER: Back on. 14 BY MR. O'BOYLE:15 Mr. Chandler, you did receive our notice for 16 Q. the Rule 2004 examination; I assume you or your attorney, 17 Would that be correct?18 For today? 19 A. Yeah. Well, no, not for today because you've 20 Q. been changing it. 21 MR. DESOUZA: There was a new one for today.22 MR. O'BOYLE: Pardon? 23 I didn't change it. The judge didn't allow you 24 A. to do the last one. 25 13 of 44 sheets Page 49 to 52 of 135 01/26/2016 10:32:45 AM 49 MR. DESOUZA: There was one for today. 1 MR. O'BOYLE: There was one for today? 2 MR. PRINCIPE: Yeah. 3 I haven't seen the notice, but I'm here. 4 A. BY MR. O'BOYLE:5 Okay. 6 Q. MR. PRINCIPE: The certificate of service says 7 it was mailed to him. 8 MR. O'BOYLE: That's good. 9 BY MR. O'BOYLE:10 Okay. In connection with your -- I guess we'll 11 Q. call it a subpoena. 12 MR. PRINCIPE: It's not a subpoena. 13 BY MR. O'BOYLE:14 Okay. The notice for the 2004 deposition -- 15 Q. examination, you were to bring multiple documents. And I 16 would like for you to give them to me now. 17 MR. PRINCIPE: I think we've provided them to 18 Mr. Desouza. 19 MR. O'BOYLE: Well, that's Mr. Desouza; that's 20 not me. 21 MR. PRINCIPE: Well, if you want to take a look 22 at them, they're here. We'll give them to you. Do 23 I have to go through that hoop to hand it to you? 24 MR. O'BOYLE: I don't know. 25 50 MR. DESOUZA: I don't know if it'll open on 1 your computer. It won't open on mine. 2 MR. O'BOYLE: It won't open on mine either. We 3 have the same problem. So unless you can give them 4 to us -- I mean, you can't give us a -- 5 Mr. Principe, you can't give us a drive and it 6 doesn't work on our computers and say that's what 7 you're getting. 8 MR. PRINCIPE: Well, we're not saying that. 9 MR. O'BOYLE: What are you saying? 10 MR. PRINCIPE: I didn't know it didn't open 11 until we got here. He will produce it. He will 12 produce it. He doesn't have a problem. 13 So we can answer Mr. O' Boyle's question, why 14 A. don't you bring that down here and let me show you right 15 now -- let me show you that this actually works. Would 16 you like to step around here, Mr. O'Boyle? 17 BY MR. O'BOYLE:18 No. 19 Q. I'll be happy to show you. 20 A. No, because we don't have -- 21 Q. MR. PRINCIPE: Let's go off the record real 22 quick. 23 THE DEPONENT: No. We're on the record. Dan, 24 come on down here. I want you to see this. 25 51 MR. O'BOYLE: We're going off the record.1 (Discussion off the record.) 2 MR. PRINCIPE: Let's go back on the record. 3 And there is the hard drive, and that's 4 A. everything that's on there. And you'll see that 5 there's -- it's a 2 terabyte drive, so it's almost 6 1.1 terabytes of data. There are -- yeah, 1.3 terabytes 7 of data. 8 MR. DESOUZA: Is this drive any different than 9 the last one that you produced at the prior 10 deposition, Joel? 11 THE DEPONENT: Well, I don't know what make or 12 model that was. 13 MR. DESOUZA: Well, I mean, the context. 14 Whether the drive is different -- 15 THE DEPONENT: There are additional documents 16 because additional documents were requested, and 17 here they are. I don't know who wants it, but Judge 18 May said you guys are doing all this together, so 19 there's one drive, which I still need to be 20 reimbursed for.21 MR. DESOUZA: Thank you.22 MR. O'BOYLE: We're on the record? 23 THE COURT REPORTER: Yes. 24 BY MR. O'BOYLE:25 52 Okay. Mr. Chandler, as far as the documents 1 Q. that you were supposed to produce, you have not produced 2 those documents, as I understand it, but rather you have 3 produced some type of a drive that could be appended to a 4 computer. And Mr. Desouza reports that he does not have 5 an Apple computer and that drive will not work on his 6 computer. So can you give us hard copies, please? 7 MR. PRINCIPE: Today? 8 MR. O'BOYLE: Yeah. Well, we're here to take 9 a -- 10 MR. PRINCIPE: How are we going to produce 11 that? 12 MR. O'BOYLE: Pardon? 13 MR. PRINCIPE: He was assuming that he had -- 14 you had the documents right here. 15 MR. O'BOYLE: Well, he can assume all he wants. 16 MR. PRINCIPE: So I guess the answer is we 17 can't produce it right now. 18 I could -- I would not be able to do that 19 A. because there are thousands and thousands and thousands 20 and thousands and thousands and thousands and thousands 21 of pages of documents on the hard drive. 22 BY MR. O'BOYLE:23 And this is one subpoena, and that's all we 24 Q. need to get those thousands and thousands and thousands 25 01/26/2016 10:32:45 AM Page 53 to 56 of 135 14 of 44 sheets 53 and thousands and thousands -- 1 And I have provided them to you. 2 A. No, you haven't. 3 Q. Yes, I have. They're right there. If you'd 4 A. like to inspect them, I've offered to let you inspect 5 them on my computer. You can open them up on your 6 computer. 7 MR. PRINCIPE: You can open them up on his. 8 MR. O'BOYLE: Yeah, but there are thousands and 9 thousands and thousands -- and I don't want to -- I 10 don't want to look at his computer, nor do I want 11 him looking at mine. 12 I'm sorry that I use a Mac and that you use a 13 A. PC. 14 BY MR. O'BOYLE:15 You shouldn't be sorry. 16 Q. It's not my problem. 17 A. You shouldn't be sorry. What you should have 18 Q. done is produced hard copies like everybody else in the 19 world, and then we wouldn't be having this discussion. 20 So let's do this. 21 Was that a question or are you just testifying 22 A. again? 23 Any and all documents provided to the Chapter 7 24 Q. trustee and/or the United States trustee in connection 25 54 with debtor's Chapter 7 case, tell me what they are. 1 MR. PRINCIPE: What have you provided to the 2 Chapter 7 trustee? 3 I couldn't tell you off the top of my head. 4 A. Whatever paperwork my attorney's asked me to produce, and 5 I've provided everything that the court's asked me to 6 provide and to the best of my knowledge all those 7 documents were -- have been placed on the hard drive that 8 I provided. 9 MR. PRINCIPE: I can go specifically. 10 BY MR. O'BOYLE:11 Any and all documents provided to the Chapter 7 12 Q. trustee and/or the United States trustee in connection 13 with the debtor's Chapter 7 case. If you have the -- 14 MR. O'BOYLE: Dan, maybe you could give Joel 15 the hard drive, and he can tell me what documents he 16 has. 17 They're on the hard drive. I couldn't tell 18 A. you.19 BY MR. O'BOYLE: 20 Okay. We can't get them off the hard drive, 21 Q. and you don't know what's on the hard drive and you had 22 an obligation to produce them. 23 And I did produce them. 24 A. Where are they? 25 Q. 55 On the hard drive. 1 A. MR. O'BOYLE: Well, Dan, you can't get them, 2 can you? 3 MR. DESOUZA: It does not open on my laptop. 4 MR. O'BOYLE: Okay. 5 MR. PRINCIPE: Or you can look at them on his. 6 MR. O'BOYLE: Ask him what documents. 7 There are so many documents. I don't know off 8 A. the top of my head which document. I don't understand -- 9 I don't understand -- yeah, I don't remember which 10 documents exactly I gave the trustee. 11 Everything that I've been asked to produce to 12 the best of my ability and to the best of my knowledge 13 I've put on that hard drive. If for some reason -- let 14 me just be clear just so everybody understands -- the 15 hard drive is encrypted. I'm happy to provide the 16 password. It's "whitepeachestastegood"; all one word; 17 lower case. White peaches taste good. I happened to be 18 eating white peaches at the time that I did that. 19 MR. DESOUZA: It's a true statement. 20 If for some reason you are unable to access 21 A. those because you don't have access to an Apple 22 machine -- I don't have access to a PC, so I don't know 23 what to do there. I would be more than happy to try to 24 make some reasonable accomodation to -- if necessary to 25 56 reformat the hard drive, if that would help or whatever. 1 I'm happy to provide all the documents there, most of 2 which have been provided previously to CAFI. 3 I'm happy to give them to you. I have given 4 them to you. If you would like me to help you change the 5 format of them, I'm happy to try to make some reasonable 6 accomodation to do that, but the records that were 7 requested were so voluminous asking me to pinpoint one 8 particular or even a few records would be very difficult. 9 BY MR. O'BOYLE:10 Would you kindly tell me what documents you 11 Q. have in response to number 1, any and all documents 12 provided to the chapter 7 trustee and/or United States 13 trustee in connection with debtor's Chapter 7 case? 14 Yeah. All the documents I gave the trustee are 15 A. on there. 16 Well, but you're supposed to produce them to 17 Q. us, not the trustee. 18 Okay. One last time. I have produced them on 19 A. a hard drive. If you-all are having some difficulty to 20 getting those, I'm happy to try to work with you to make 21 them more accessible. It seems that the issue is I use a 22 Mac and you use a PC. 23 Most of the documents -- a lot of them are 24 PDFs, which shouldn't be an issue. I'm certainly happy 25 15 of 44 sheets Page 57 to 60 of 135 01/26/2016 10:32:45 AM 57 to try to work -- and Dan can tell you when I produced 1 documents previously for CAFI, I was very happy to try to 2 make accommodations to make sure he'd get them. I have 3 produced the records. If you want me to try to work with 4 you to make them more accessible, I'm happy to do that.5 MR. O'BOYLE: We're going to have to come back 6 to finish Mr. Chandler's. 7 MR. PRINCIPE: That's fine. I don't have a 8 problem with that. Let me go off the record real 9 quick. Let me go off the record. 10 MR. O'BOYLE: Stay on the record. And I would 11 expect when I come back to have 36 files or piles 12 or -- 13 MR. PRINCIPE: You're not going to get them 14 because I've objected to some of them. 15 MR. O'BOYLE: Okay. The ones you objected 16 to -- 17 MR. PRINCIPE: And Mr. Gomez and I talked about 18 it and we were going to argue -- not argue, but talk 19 about what should be and what shouldn't be. So 20 subject to that objection, we're not producing it 21 yet until we can work it out. 22 Now, if Mr. Gomez is not working -- is not 23 working for you, then you and I need to go over the 24 objection that was actually put in the protective 25 58 order; and remember, Mr. Gomez, who was representing 1 you at that time indicated to the judge that we're 2 going to try to work out the document request. 3 MR. O'BOYLE: Right. And I don't know what 4 occurred. I mean, I just don't know. 5 MR. PRINCIPE: You were there. 6 MR. O'BOYLE: Work out the document request? 7 MR. PRINCIPE: Well, that's what I'm saying, 8 but it's in the objection. Now, I can ask him if 9 you'd like me to help you along here, you know, are 10 the tax returns that you provided to the trustee on 11 that document? 12 THE DEPONENT: I believe they are, yeah. 13 MR. PRINCIPE: Those type of questions he might 14 be able to answer. 15 MR. O'BOYLE: Okay. Well, let's look at them. 16 MR. PRINCIPE: Can you pull up your tax 17 returns? 18 THE DEPONENT: I really don't want them going 19 over my -- playing on my computer. I'm happy -- I'd 20 be happy to -- if we can accommodate putting them on 21 the screen, I'd be happy to do that. I'd be happy 22 to reformat that. 23 MR. PRINCIPE: Can you put it on the screen? 24 THE DEPONENT: I don't know whether we can or 25 59 not. My point is I'm happy to help you get access 1 to them. I'm sorry that you don't have the ability 2 to open a hard drive that was formatted on a Mac. I 3 don't own a PC. 4 MR. DESOUZA: Let's go off the record for two 5 minutes. Marty, come over here.6 MR. O'BOYLE: Okay. 7 (Recess from 3:12 p.m. to 3:21 p.m.)8 BY MR. O'BOYLE:9 Joe, I'm not going to ask any more questions 10 Q. about this today, because we wasted already too much 11 time. So let's move along, if we can. 12 MR. PRINCIPE: And we'll agree you can take it 13 once we get the docs like that, and then we'll iron 14 out our objections. I don't have a problem. 15 MR. O'BOYLE: That's fine, Frank. Are we back 16 on the record? 17 THE COURT REPORTER: Yes, sir, we were.18 MR. O'BOYLE: Good. 19 BY MR. O'BOYLE:20 Mr. Chandler, I'm looking again at your 21 Q. schedule in connection with the bankruptcy that you filed 22 that is currently pending, and I see on creditors holding 23 unsecured -- unsecured nonpriority claims that there 24 is -- 25 60 MR. PRINCIPE: What page number? 1 MR. O'BOYLE: It's page 15 of 47. 2 MR. PRINCIPE: Thank you, sir. 3 BY MR. O'BOYLE:4 And it's in connection with Citizens Awareness 5 Q. Foundation, and it says "debtor disputes that he owes any 6 money to this creditor." Do you dispute that you owe any 7 money to the creditor? 8 Yes. 9 A. And on what basis do you dispute that you 10 Q. owe -- don't owe any money to that creditor? 11 I don't owe them any money. 12 A. On what basis I said? 13 Q. The truth and the facts.14 A. And what are the facts that would show you 15 Q. don't owe them any money? 16 I didn't borrow any money from them. 17 A. That doesn't mean you don't owe them any money? 18 Q. MR. PRINCIPE: Is that a question? 19 MR. O'BOYLE: Yes. 20 BY MR. O'BOYLE:21 That doesn't mean -- does it? 22 Q. I didn't borrow any money from them. I don't 23 A. have anything I would be -- I don't see how I owe them 24 any money. 25 01/26/2016 10:32:45 AM Page 61 to 64 of 135 16 of 44 sheets 61 Okay. But as far as factually, can you tell me 1 Q. why you don't owe them any money? 2 I'd have to go back and review my notes, in 3 A. particular the motion to dismiss that I filed in 4 connection with that case. 5 Now, several times today you've referred to 6 Q. your notes. 7 Uh-huh. 8 A. Would you kindly bring them with you tomorrow? 9 Q. No, I won't. 10 A. MR. O'BOYLE: Counsel? 11 MR. PRINCIPE: It hasn't been requested. Have 12 you requested it? 13 MR. O'BOYLE: I'm not sure I didn't reread -- 14 the documents we asked for were from March, so I 15 haven't reread them. 16 MR. PRINCIPE: Yeah. If you ask and we agree, 17 then -- but right now I don't know what documents or 18 what frame it is. As long as it pertains to the 19 bankruptcy or anything else, I wouldn't have any 20 objection, but I don't know if he can get it here by 21 tomorrow. You say can he get them here by tomorrow? 22 MR. O'BOYLE: Well, they're in his notes, which 23 they're in his possession. And I can't imagine that 24 it's -- 25 62 MR. PRINCIPE: But part of it is -- and I don't 1 know -- I'm not speaking for you, but part of it 2 would be his notes may be his motion to dismiss. 3 MR. O'BOYLE: Motion to dismiss? 4 MR. PRINCIPE: He has filed a motion to 5 dismiss, my understanding, that CAFI claim. 6 MR. O'BOYLE: Okay. 7 MR. PRINCIPE: And that's what he's saying. Is 8 that part of your -- 9 THE DEPONENT: That's what I'm saying. I said 10 I filed a motion to dismiss. 11 MR. O'BOYLE: I just want to be clear. That 12 may not be a no, but it may be something that --13 THE DEPONENT: There are certainly, you know, 14 mental impressions that I wrote down in preparation 15 for that, which certainly are not subject to 16 disclosure. 17 MR. O'BOYLE: Counsel? 18 MR. PRINCIPE: I agree. 19 MR. O'BOYLE: That mental impressions are not 20 subject to disclosure? 21 MR. PRINCIPE: I think they are, but -- 22 As I'm acting as my own counsel, no, they're 23 A. not. 24 BY MR. O'BOYLE:25 63 Well, you're not acting as your own counsel 1 Q. here. 2 In that lawsuit I am. 3 A. Not here. 4 Q. In that lawsuit -- and let me be clear. In 5 A. that lawsuit I am acting as my own counsel. I am not 6 obliged to -- unless Judge May tells me otherwise, I'm 7 not obliged to disclose every solitary note that I've 8 made or mental impression that I've created in 9 preparation for legal pleadings in a case that are beyond 10 the scope of this bankruptcy. 11 MR. O'BOYLE: One second, please. 12 MR. PRINCIPE: If you request it, then we'll 13 take a look at it. And then if there's an 14 objection, we'll make an objection.15 And by the way, many of the notes that I'm 16 A. referring to are on the hard drive that I've provided to 17 you. 18 MR. O'BOYLE: Please bear with me for half a 19 minute here. 20 MR. PRINCIPE: Sure. Do you know what's on 21 that hard drive? Go off the record real quick. 22 (Discussion off the record.) 23 MR. O'BOYLE: Back on the record. 24 BY MR. O'BOYLE:25 64 Mr. Chandler, the summary of schedules that you 1 Q. and Mrs. Chandler signed under oath, are they true or 2 were they true and correct on the day you signed them? 3 I believe that they were, yes. 4 A. Is that a yes or a no? 5 Q. I believe that they were, yes. 6 A. Okay. So they might not have been? 7 Q. MR. PRINCIPE: I think he answered the 8 question. 9 MR. O'BOYLE: That's another question. 10 BY MR. O'BOYLE:11 Is that correct? 12 Q. I signed them under penalty of perjury that 13 A. they are true to the best of my knowledge, yes. I 14 believe that they are true. 15 Okay. The signature line doesn't say to the 16 Q. best of your knowledge, and that would be on page 34 of 17 37 -- 47, I'm sorry. 18 I'm sorry, which page? 19 A. 34. 20 Q. Yes. I attested that they are true and 21 A. correct. I believe that I answered that correctly. 22 Okay. So that is a correct statement? 23 Q. Yes. I believe that to be true, yes. 24 A. And your signature where it says -- I'm going 25 Q. 17 of 44 sheets Page 65 to 68 of 135 01/26/2016 10:32:45 AM 65 to abbreviate -- that they are true and correct, that is 1 a correct statement, right?2 Yes. I believe that it is. 3 A. Okay. And it was a correct statement when you 4 Q. signed it; is that correct? 5 Yes. 6 A. Okay. Tell me about CAFI. 7 Q. I'm sorry? 8 A. Tell me about CAFI. 9 Q. MR. PRINCIPE: Can you narrow the question? 10 MR. O'BOYLE: Sure. 11 BY MR. O'BOYLE:12 What do you know about CAFI? 13 Q. MR. PRINCIPE: Again, in what context and can 14 you narrow it again? Do you have a specific 15 question? 16 BY MR. O'BOYLE:17 Yeah. What do you know about CAFI? 18 Q. MR. PRINCIPE: Well, no; a specific question; 19 not a broad question. There's two different things. 20 MR. O'BOYLE: Well -- 21 MR. PRINCIPE: Because if you ask a broad 22 question and he answers something, you're going to 23 ask him another question because it didn't pertain 24 to the question. 25 66 MR. O'BOYLE: But if I asked narrow questions, 1 Frank, I may ask him 50 questions, and I'm trying to 2 avoid that. 3 When you say CAFI what do you mean?4 A. BY MR. O'BOYLE: 5 Same thing you mean when you say CAFI. 6 Q. How could you possibly know what I mean?7 A. Well -- 8 Q. Are we talking about the Citizens Awareness 9 A. Foundation, Inc., is that what we're talking about? 10 Yes. 11 Q. Okay. Just want to be sure that that's what 12 A. we're talking about. 13 Yes; same. 14 Q. Asking me what I know about it is just 15 A. extraordinarily broad. I wouldn't even know where to 16 begin. 17 Well, just try. 18 Q. MR. PRINCIPE: Tell him what you think about 19 CAFI. 20 Yeah. Citizens Awareness Foundation was 21 A. created in I want to say it was January of 2014, I 22 believe. It was a corporation that I worked for for a 23 few months. It was based in Deerfield Beach. 24 MR. PRINCIPE: You can keep going. He asked 25 67 you the question what do you know; keep going. 1 I became involved with Citizens Awareness 2 A. Foundation after you invited me down to your home in 3 south Florida, and we met and talked about you creating a 4 foundation -- funding a foundation. We talked about the 5 possibility of me working for the foundation. 6 We talked back and forth over the course of 7 several days about what that might look like, the 8 particulars about what that employment would involve, as 9 far as compensation and job responsibilities. It was 10 created as a corporation I believe it was on -- I want to 11 say January 27, 2014, but I'm not certain of that. And I 12 went to work for the foundation literally as it was 13 created. And I worked as the executive director. I was 14 hired by you, and I worked there until I think it was 15 June 30th of 2014 when I resigned. 16 BY MR. O'BOYLE:17 During the time that you were with CAFI -- 18 Q. well, strike that.19 The agreement that you had with CAFI was called 20 a memorandum of understanding; am I correct?21 Yes. 22 A. Okay. And that memorandum of understanding was 23 Q. prepared by who? 24 I prepared it at your direction. 25 A. 68 Okay. And when you prepared it you were quite 1 Q. satisfied with it, were you not? 2 I had preferred to actually have an employment 3 A. contract and you didn't want to do that. And I think as 4 a good way -- by way of compromise, we agreed that we 5 agreed to do a memorandum of understanding. And, again, 6 I'd have to go back and check my e-mails, but, as I 7 recall, we sent back and forth a couple of different 8 versions, and it was the compromised version that we 9 ultimately agreed to. 10 Have you ever said that you prepared it? 11 Q. Yeah. I believe I have. 12 A. Okay. You made several statements in writing 13 Q. and otherwise that you were supposed to be the only 14 person who had, for lack a better way of saying it, the 15 say in CAFI; am I correct? 16 No. I don't think that would be accurate. 17 A. Okay. So you're saying -- well, then tell me 18 Q. what is accurate. 19 About what? 20 A. What I just said. 21 Q. You just asked me if that was accurate. It's 22 A. not accurate. I don't believe your characterization is 23 true. I don't believe that's anything that I've said. 24 Okay. So what would be accurate? 25 Q. 01/26/2016 10:32:45 AM Page 69 to 72 of 135 18 of 44 sheets 69 About what? 1 A. What we just spoke about. 2 Q. You asked me if it's accurate. I said it's not 3 A. accurate. 4 And I said what would be accurate? 5 Q. About what? 6 A. About the -- what's it called -- the memorandum 7 Q. of understanding. 8 What would be accurate about it? 9 A. Uh-huh. 10 Q. MR. PRINCIPE: Can you go back and read the 11 statement that he made and then he said "no, it's 12 not accurate" so he understands it, please?13 THE COURT REPORTER: Sure. 14 (The preceding question was read by the court 15 reporter.) 16 BY MR. O'BOYLE:17 What was compromised from the first draft that 18 Q. you prepared to the final draft? What was compromised? 19 I'd have to go back and compare them. I 20 A. couldn't tell you off the top of my head. 21 Okay. Do you remember anything that was 22 Q. compromised? 23 I'd have to go back and compare them. 24 A. Okay. And do you -- do you deny that you said 25 Q. 70 that you were supposed to be in complete control of CAFI? 1 I don't recall ever saying that. 2 A. Okay. But if I can show you that you did, 3 Q. you'd agree that that was a true statement because you're 4 an honest man, correct?5 I don't recall having said that. I don't 6 A. recall uttering those exact words. 7 Oh, I didn't say exact words; in concept. 8 Q. MR. PRINCIPE: Define "concept." 9 MR. O'BOYLE: Generally stated. 10 I don't believe that I've ever uttered that, 11 A. not those words. 12 BY MR. O'BOYLE:13 Again, I didn't say those words. 14 Q. Well, what words -- you're asking if I said 15 A. certain things. Without knowing what exact words you're 16 asking me I said, I couldn't begin to tell you whether -- 17 I don't recall ever using those words. The exact words 18 in the context would certainly have some bearing on my 19 recollection, I'm sure. 20 Okay. Did you ever prepare a timeline? 21 Q. MR. PRINCIPE: For what? 22 MR. O'BOYLE: I'm going to say for his 23 employment with CAFI, but I don't know -- I think 24 that works. 25 71 I don't recall ever preparing any timelines for 1 A. CAFI. As it relates to when I was employed with CAFI, I 2 don't recall. 3 BY MR. O'BOYLE:4 I didn't say when it relates to -- in 5 Q. connection with CAFI. I didn't say for CAFI, and I 6 didn't say during -- while you were there and so forth. 7 I prepared a timeline in preparation for a 8 A. conversation that I had with Bob Sweetapple relating to 9 my employment with CAFI, yes. 10 Why would you do that? 11 Q. I find timelines to be helpful. They're a 12 A. great way for me personally to refresh my memory and to 13 put things in context. Sometimes it's helpful to 14 visualize things in chronological order. 15 But why would you prepare in connection with 16 Q. your meeting with Bob Sweetapple? 17 In order to refresh my memory about the 18 A. conversation I anticipated we were going to have. 19 How did you know you were going to have 20 Q. conversations regarding the timeline? 21 Well, I don't think we're going to have 22 A. conversations about the timeline. I prepared the 23 timeline as a way of refreshing my memory about the 24 events that unfolded prior to, during, and subsequent to 25 72 my employment with CAFI. 1 MR. O'BOYLE: Okay. Can you mark this as an 2 Exhibit, please? 3 THE DEPONENT: Sure. 1?4 MR. O'BOYLE: Yeah. Exhibit 1, yeah. 5 (Exhibit 1 marked for identification.) 6 MR. PRINCIPE: Is it a composite or is it just 7 one exhibit? 8 MR. O'BOYLE: Just one. 9 Let me take a look at that real quick.10 A. BY MR. O'BOYLE: 11 Joe, why don't you let Frank look at it because 12 Q. I'm going to leave it with you? 13 Are we going to talk about this? 14 A. Yes, we are. 15 Q. Well, then let me just flip through it real 16 A. quick. I don't need to read every word of it. 17 All right. Go ahead. 18 Q. Okay. Go ahead. 19 A. Okay. You prepared that for Mr. Sweetapple? 20 Q. I don't know if I prepared that. I prepared a 21 A. timeline. I couldn't vouch for that. I'd have to go 22 through and actually compare that to what I had in my 23 records, but -- 24 Okay. 25 Q. 19 of 44 sheets Page 73 to 76 of 135 01/26/2016 10:32:45 AM 73 -- I did prepare a timeline that that looks 1 A. familiar. I can't verify that that's a true -- 2 How could you verify it? 3 Q. I'd have to compare it to the documents that 4 A. are in my notes and the documents that I've already 5 provided to you on the hard drive. The timeline that I 6 prepared is on the hard drive. 7 Okay. But you would agree that the information 8 Q. that's in there came generally from you? There may be 9 something that might have been changed, but generally 10 from you, correct?11 In the timeline that I prepared. 12 A. Yeah. But if you looked at that you would 13 Q. recognize a lot of the entries, wouldn't you, or would 14 you recognize nothing? 15 I said that it looks -- it looks familiar to 16 A. me, but I cannot say with certainty without taking a lot 17 of time right now to compare them. 18 Okay. 19 Q. I cannot vouch that what you've provided as an 20 A. exhibit is what you're purporting it to be. I presume it 21 is, but I don't know that. I did prepare a timeline.22 MR. O'BOYLE: Mr. Principe, if you would when 23 you're finished looking at it, give that to 24 Mr. Chandler and let him read it and then you can 25 74 tell me that what in that timeline you did not 1 prepare, because you certainly recognize your own 2 language. 3 MR. PRINCIPE: Those questions do pertain to 4 CAFI's lawsuit, correct, that you're going to ask 5 and they're relevant to a 2004 exam? 6 MR. O'BOYLE: They're relevant to a 2004 exam. 7 They're relevant to CAFI. They're relevant to 8 Gulfstream. They're relevant to Sweetapple. 9 MR. PRINCIPE: If they're relevant to CAFI, 10 then okay. CAFI's listed as a potential claim in 11 the bankruptcy. 12 MR. O'BOYLE: I understand. The world doesn't 13 start and stop with CAFI. 14 MR. PRINCIPE: Then ask your questions. 15 MR. O'BOYLE: Could you mark that? 16 (Exhibit 2 marked for identification.) 17 (Recess from 3:53 p.m. 4:01 p.m.) 18 You'll have to refresh my question. 19 A. BY MR. O'BOYLE:20 Sure. Did you prepare this to the best of your 21 Q. knowledge? 22 I don't know. There are a number of pages that 23 A. are cut off, so I can't say with certainty.24 Show me which pages are cut off. 25 Q. 75 Well, they're not numbered, so it'll be 1 A. difficult to -- 2 Oh, I don't think so. 3 Q. This page is cut off. 4 A. What's it say? What's the first word that's on 5 Q. there? 6 It's cut off. "Affy details such as the 7 A. purchase." 8 Okay. All right. Now, let's just wait one 9 Q. second and go to the prior page. If you remember, this 10 was one long sheet. So when you cut it, you can't cut 11 perfectly obviously, but it's not cut off. It's just 12 repetitive. It's in total on this page and partial on 13 the next page. 14 Okay. I see. 15 A. And every single page that you find you will 16 Q. see that. Every single page as you would say cut off you 17 will see -- 18 I see. Yeah, as far as authenticating it, I 19 A. mean, it looks familiar to me. Without comparing it to 20 what I prepared, what I'm certain I prepared, I couldn't 21 say with certainty that it's verbatim what I created, but 22 it certainly looks familiar. 23 Okay. Now, you say in here that Bill Ring 24 Q. denied Chandler's request to give a case to Thomas M. 25 76 Osiero. 1 Where -- 2 A. MR. PRINCIPE: Hang on again. Objection. Is 3 it relevant to a 2004 exam? 4 MR. O'BOYLE: I think so. 5 What date is that? 6 A. BY MR. O'BOYLE:7 Joel, it's -- it looks like June 10th. 8 Q. MR. PRINCIPE: Of what year? 9 MR. O'BOYLE: 2014. This, Frank, is just his 10 tenure at CAFI. 11 Okay. The June 4 actually would have been I 12 A. think on a timeline June 2nd because if this is what I 13 created -- and, again, I'm not authenticating it, so 14 yeah, e-mail to Chandler June 2, 2014, 4:52 p.m. Is that 15 the one you're talking about? 16 Bear with me. No, I was speaking about the 17 Q. next one, but we could talk about that one, the June 4th. 18 That's fine. 19 Okay. What would you like to talk about?20 A. Okay. Do you have a copy of that e-mail? 21 Q. I believe that I do, and I've provided it to 22 A. CAFI, to Dan back last year with the first request for 23 production, and then it's also on the hard drive that I 24 provided today. 25 01/26/2016 10:32:45 AM Page 77 to 80 of 135 20 of 44 sheets 77 MR. O'BOYLE: Dan, can you give Mr. Chandler 1 the hard drive and can you pull it up for us, that 2 one document? 3 MR. DESOUZA: I think he has it right now. 4 MR. O'BOYLE: Oh, he has it, okay. 5 There are many records on there. I don't know 6 A. how long it might take me to find it. 7 BY MR. O'BOYLE:8 You can do a search and we can go on. 9 Q. Okay. Sure. 10 A. After you start your search, Joel, we'll 11 Q. continue. 12 Okay. I have it. 13 A. You do have it? 14 Q. Uh-huh. 15 A. Okay. 16 Q. Just for future reference, make it easier for 17 A. you guys, it's in the folder that says "Bob Sweetapple," 18 and it's a PowerPoint file. It was actually created 19 using a different program, but it can be viewed in 20 PowerPoint. 21 So Sweetapple has -- in other words, when you 22 Q. say it's under folder -- under Sweetapple, Sweetapple has 23 a copy, correct?24 I don't know that with certainty. It's 25 A. 78 possible that he does. Just because it's in that folder 1 doesn't mean that those are documents that I gave to 2 Sweetapple necessarily. They would have been records 3 that appeared to me to be responsive to whatever document 4 request was made. 5 To whom; by whom? 6 Q. CAFI or by you in connection with the 2004 7 A. exam. 8 Okay. I have no documents, as you know. 9 Q. I'm sorry? 10 A. I said I have no documents, as you know. 11 Q. Well, I provided them to you, but you're 12 A. disputing that. 13 Okay. Can you read that letter into the 14 Q. record? 15 I'm sorry. I thought you wanted me to pull the 16 A. timeline. 17 Oh, no. No. The letter, Joel, I'm sorry; the 18 Q. one that says June 4th that you were just talking about. 19 Oh, the e-mail is what you're talking about. 20 A. Yeah. Yeah. That's why I said if you do a 21 Q. search, while it's searching we can move on. 22 Hold on. Let me find that. That's June 2nd. 23 A. Yeah, I have it. The date and the time stamp I'm saying 24 is a little bit different, but it's June 2nd. 25 79 Okay. 1 Q. Yeah. It says from Bill Ring to Joel Chandler, 2 A. Denise Dimartini, Brenda Russell, and then a CC to 3 William Ring. "Denise and I are speaking to Mr. Tweel of 4 Jackson Kelly again this week; most likely Weds" -- 5 presumably Wednesday or Friday -- "however, at this point 6 I'm not inclined to authorize CAFI to engage in another 7 law firm" -- 8 THE COURT REPORTER: I'm sorry? Can you please 9 repeat that? 10 THE DEPONENT: I'm sorry. Yeah. I forgot you 11 were doing that. 12 THE COURT REPORTER: "However, at this point 13 I'm not inclined to" -- 14 THE DEPONENT: -- "authorize CAFI" -- that's 15 C-A-F-I -- "to engage another law firm based upon my 16 last conversation with Tweel," which is T-W-E-E-L. 17 "We will get back with the definitive answer after 18 that conversation." 19 BY MR. O'BOYLE:20 And that's it? 21 Q. That's all that's in that particular -- 22 A. Letter? 23 Q. In that particular e-mail, yeah. 24 A. Okay. How did that sit with you? 25 Q. 80 I thought it was problematic for a number of 1 A. reasons. One was the -- this was a concern that you and 2 I discussed very early on, that I thought it was 3 important for CAFI to use more than one law firm other 4 than just your son's law firm for a number of reasons, 5 not the least of which is to avoid the appearance of any 6 impropriety with respect to self-dealing because of your 7 financial interest in both the foundation and the firm. 8 I thought that it would -- my suggestion that 9 you and I discussed and conversations that I had with the 10 board about this was that it didn't necessarily need to 11 be a large number of cases, but at least some cases 12 should be given to other law firms besides the O'Boyle 13 Law Firm. So I wasn't enthusiastic about it, and I 14 thought it was imprudent to take that course. 15 And who -- if Ring would have said "go ahead," 16 Q. who would you have given this case -- and I don't know 17 what case it is? 18 Yeah. The particular case you're talking about 19 A. was actually quite an interesting case. It's a shame it 20 didn't get litigated. Barnes and Nobles college book 21 sellers who actually have been sued over the exact same 22 set of facts in a case that went to the Fourth DCA; I 23 mean, identical facts. And Thomas & LoCicero had 24 expressed an interest in the case, and they found out 25 21 of 44 sheets Page 81 to 84 of 135 01/26/2016 10:32:45 AM 81 about the case because the time I actually went out to 1 USF and visited Barnes and -- they operate the book store 2 on campus. 3 And they stand in the shoes of the university, 4 and what I asked for were copies of the adoption forms. 5 And these are forms that are circulated by the bookstore 6 to the university faculty for books that they need for 7 upcoming coursework. And these are forms that are 8 requested by off-campus book sellers who are competitors 9 of Barnes and Nobles. And Barnes and Nobles was sued 10 back in I want to say '88 or '89 -- I think a Fourth 11 DCA -- because they refused to give them up claiming that 12 they were proprietary, and the court said that they 13 weren't proprietary, that they collected those on behalf 14 of the university. 15 Well, I went there and made the same public 16 records request to USF. They told me the same thing, and 17 my brother happened to -- we met for lunch, and he 18 happened to follow me on the campus in his vehicle, and 19 we -- he was there, and he made a similar public record 20 request; not the same request, but a similar request the 21 same -- about the same time on the same visit. And he 22 had had a conversation with one of the attorneys at 23 Thomas & LoCicero that he was friendly with, and they had 24 expressed an interest in it. And I thought that given 25 82 the fact that Greg Thomas, who's a senior partner at 1 Thomas & LoCicero, is so highly regarded on both sides of 2 the public records issues, even people who are 3 adversarial towards open government -- that him -- that 4 Thomas & LoCicero being willing to represent the 5 foundation would have added to the foundation's 6 credibility; besides the fact that a large number of the 7 most important appellate cases on open government issues 8 have been argued by Greg or one of his partners. 9 How about -- what would you say if I told you 10 Q. that Bob Tweel -- a senior member of the largest law firm 11 in West Virginia that's 200 years old -- said for the 12 first year you don't need to go outside of where you are, 13 would you say that I'm lying to you? 14 No. I couldn't possibly know. 15 A. Okay. 16 Q. If he told you that in the conversation, then I 17 A. guess -- you know, I wasn't there. 18 So then you don't know what Tweel said, 19 Q. question mark? 20 Yeah. The only time that I remember having a 21 A. -- being involved in any way in a conversation, ever 22 hearing any words come out of somebody's mouth named Bob 23 Tweel was in your office on a conference call very, very, 24 very early in the beginnings of CAFI, when there were 25 83 discussions about just sort of the -- you know, how does 1 all this work, as far as having a 501 C3. So I don't 2 recall other than that having any conversations with Bob 3 Tweel, so I don't know what he said or he didn't say. 4 Okay. 5 Q. My -- my argument for engaging another law firm 6 A. on at least some case -- and not just one other law firm; 7 several other law firms on, you know, a case here, a case 8 there, would have been I think what -- I think what I 9 proposed to Bill Ring and then Denise Demartini, the two 10 board members that I -- 11 THE COURT REPORTER: I'm sorry? 12 THE DEPONENT: I'm sorry. 13 THE COURT REPORTER: You said there would have 14 been I think what -- 15 THE DEPONENT: Bill Ring -- R-I-N-G -- and then 16 Denise Demartini -- I don't know -- the only two 17 board members that I ever met with together; I think 18 what I was proposing was maybe two or three or four 19 or maybe five cases a month -- probably not that 20 many -- be given to other law firms. And it 21 wasn't -- I wasn't making an argument that there was 22 any legal requirement that the foundation do that. 23 I was arguing that it was a -- politically would 24 have been prudent to do, for the sake of appearance. 25 84 BY MR. O'BOYLE:1 Right. 2 Q. And -- and if -- if someone like John Kaney or 3 A. Andrew Moganen or Greg Thomas or Ed Mullins or some of 4 these other well-known, highly regarded open government 5 litigators were willing to represent the foundation, it 6 would add to the foundation's credibility. 7 I see. Okay. At the time, June 4th, 2014, you 8 Q. would have liked to have used Thomas & LoCicero, if I'm 9 saying it -- 10 Thomas & LoCicero. 11 A. Right? 12 Q. Yeah -- what day did you just give me? 13 A. Well, I said as of June 4th you wanted to use 14 Q. them? 15 MR. PRINCIPE: And you were still under the 16 employment of CAFI, correct? 17 THE DEPONENT: Yeah. Yeah. 18 In that -- in that -- in that time frame, you 19 A. know, there's an -- there's an e-mail exchange on 20 June 2nd. I'd have to -- again, without taking more 21 time -- well, yeah, earlier in that day there was -- 22 earlier that day there was another e-mail exchange with 23 Bill. This is I think the -- yeah, this is where I 24 actually raised this issue with him, and I wrote going 25 01/26/2016 10:32:45 AM Page 85 to 88 of 135 22 of 44 sheets 85 back to a phone conference that Marty and I had with Bob 1 Tweel, "the issue of using the law firm other than the 2 O'Boyle Law Firm has come up. The rationale is that if 3 we use the O'Boyle Law Firm exclusively it will appear to 4 be self-dealing by the IRS. Although we have not been -- 5 we have not been any concrete suggestions -- obviously 6 that's a typo -- as to how many cases should be referred 7 elsewhere, the consensus has been that we should refer at 8 least some elsewhere. 9 "With that in mind, I would like the board to 10 authorize me to engage Thomas & LoCicero, TLO, T-L-O, to 11 take one case, CAFI versus Barnes and Nobles. My brother 12 Robert was with me when I visited the USF campus 13 bookstore. The bookstore is operated by Barnes and 14 Nobles. Robert mentioned the facts of the case to one of 15 the attorneys at TLo, and they have expressed an interest 16 in the case. I have not yet discussed it -- I have not 17 yet discussed it with TLo. TLo is the preemptive open 18 government law firm in the state. Greg Thomas, the 19 firm's senior partner, has argued many of the landmark 20 public records cases, many of which are regularly cited 21 in briefs, written by the O'Boyle Law Firm." 22 MR. PRINCIPE: Slow down. 23 THE DEPONENT: Sorry. 24 MR. PRINCIPE: She's trying to transcribe. 25 86 THE DEPONENT: Just kick me or something if I 1 keep going too fast. 2 THE COURT REPORTER: "Many of the landmark 3 public records cases" -- 4 THE DEPONENT: Yeah. "Many of which are 5 regularly cited and briefs written by the O'Boyle 6 Law Firm. I would ask them to take the case on the 7 same terms as the O'Boyle Law Firm contingency, with 8 the firm bearing all litigation costs. I suspect 9 that TLo is interested in the Barnes and Nobles case 10 because it is in Tampa and because Barnes and Nobles 11 was sued over virtually identical facts in a case 12 that made its way to the Third DCF" -- I said Fourth 13 earlier; it's the Third DCA -- "a number of years 14 ago. I think an appellate decision is what TLo is 15 most interested in. Let me know if there are any 16 questions or concerns. I think we need to refer 17 something to someone other than the O'Boyle Law 18 Firm, and this would be a good case to use for that 19 and TLo would always be my first choice. It will 20 enhance the standing of the foundation." 21 BY MR. O'BOYLE:22 Do you know what kind of lawyer Bob Tweel is? 23 Q. A tax attorney, as I understand it. 24 A. That's correct. And you just read that you 25 Q. 87 were -- you, Joel, were worried about the IRS. 1 Among other things. I also say in the e-mail 2 A. to Bill that I believe it would enhance the standing of 3 the foundation. 4 Okay. But what you're saying is Bob Tweel 5 Q. doesn't know what he's doing? 6 MR. PRINCIPE: No that's not what he said. 7 Object to question. Ask him a question. 8 MR. O'BOYLE: Okay. 9 BY MR. O'BOYLE:10 Bob Tweel, you agree, is a tax lawyer?11 Q. Yes. As far as -- that's what I've been told. 12 A. I don't know that. 13 Okay. Well, we can go on the Web and look, if 14 Q. you need. 15 Right, because everything is accurate. 16 A. And you were worried about the IRS? 17 Q. That was one consideration. 18 A. I understand, but you were worried about it; 19 Q. you just read it. Let's read it again. Well, just that 20 one sentence. 21 Yeah. "The rationale is that if we use the 22 A. O'Boyle Law Firm exclusively it will appear to be 23 self-dealing by the IRS." 24 Okay. So where did that come from? 25 Q. 88 That was my understanding from the conference 1 A. call that we had with Bob when I was in your office. For 2 example, you saying a few minutes ago when you stated on 3 the record that Bob said it was okay for the first year. 4 I don't remember whether that's -- that's not my -- I'm 5 not saying it's not what he said. That's not my 6 recollection -- and this is going back a long time ago of 7 the conversation, but that there was the possibility of 8 the appearance of self-dealing. 9 And as I expressed to you and as I expressed to 10 the board both verbally and in writing when I gave them a 11 written warning that I was contemplating leaving, that 12 being involved in Civil Rights activism as I have been 13 for a fair number of years, it has been my experience 14 that if you give the establishment an opening to come 15 after you they will take it. Even when it's trumped up, 16 nonsensical poppycock they will take it and that trying 17 to stay as far away from anything that looks unsavory or 18 questionable is best. 19 Okay. Next time you speak to your lawyers ask 20 Q. them this question, if you don't mind, and that is if you 21 get an opinion from a tax lawyer is there any liability 22 that follows if you do something wrong and the lawyer has 23 opined? 24 Yeah, but as I was just saying, my concern was 25 A. 23 of 44 sheets Page 89 to 92 of 135 01/26/2016 10:32:45 AM 89 not principally a technical violation of the law. 1 That's -- that's not what I'm expressing in the e-mail; 2 that's not certainly what I -- not what I intended to 3 express in the e-mail that I sent to Bill. It's an 4 appearance issue. It was trying to -- I mean, you were 5 going around with the foundation; filed a lot of lawsuits 6 against the establishment, as you yourself have filed a 7 lot of lawsuits against the establishment, as I have. 8 And they get fired up. I mean, your RICO case is a good 9 example. It doesn't matter whether the facts are good or 10 bad or nonsensical. They have very deep pockets, deeper 11 than anybody in this room. 12 Who's "they"? 13 Q. The establishment. 14 A. I see, okay. 15 Q. They don't have to have good facts, because it 16 A. doesn't cost them a penny if they're wrong. It's the 17 taxpayers that pay. They have virtually unlimited 18 resources, even a little town like Gulfstream, for 19 example. It doesn't matter whether a RICO prosecution 20 makes sense or doesn't make sense. They can still spend 21 a bunch of money doing it. They can still harass people 22 by filing -- trying to prosecute people civilly or 23 criminally. And so my point was that to try to stay as 24 far away from anything that would either invite that or 25 90 that would give the establishment cover for doing it. 1 Okay. We sued the Atlantic City press? 2 Q. MR. PRINCIPE: Who's "we"? 3 MR. O'BOYLE: Me and I think Bill Ring 4 represented me, but I'm not sure. It may have 5 been -- 6 Okay. 7 A. BY MR. O'BOYLE:8 And guess who was representing the Atlantic 9 Q. City press? Thomas & LoCicero. 10 Okay. 11 A. Would you want us to hire a law firm that we 12 Q. are adversary -- in an adversarial relationship with? 13 I'm not sure I understand the question. 14 A. Okay. 15 Q. I'm sorry. It's getting late in the afternoon. 16 A. Just kind of break it down for me a little more. 17 Sure. Thomas & LoCicero -- 18 Q. LoCicero. 19 A. -- represented our adversary? 20 Q. We're talking about Thomas & LoCicero? 21 A. LoCicero, yeah. 22 Q. Okay. 23 A. I'm not saying it right. 24 Q. TLo is what they go by. 25 A. 91 Okay. TLo was representing Atlantic City 1 Q. press? 2 Okay. 3 A. How could we -- or CAFI as the case may be -- 4 Q. have hired them -- that firm -- when they were adverse? 5 How could that have happened? 6 Who were they adverse to? 7 A. They were adverse to me, but it's -- we're all 8 Q. in the same world. 9 MR. PRINCIPE: Do you have a date? Do you have 10 dates? 11 MR. O'BOYLE: Before -- 12 MR. PRINCIPE: That way he's clear what was the 13 law firm. 14 MR. O'BOYLE: It was during the June 4th, 2014. 15 MR. PRINCIPE: Okay. 16 BY MR. O'BOYLE:17 So that's why Bill Ring wouldn't go along with 18 Q. the program and -- 19 MR. PRINCIPE: Is that a question? 20 MR. O'BOYLE: Pardon? 21 MR. PRINCIPE: Please ask a question. 22 MR. O'BOYLE: Yeah. I'm going to do it. 23 MR. PRINCIPE: Okay. 24 BY MR. O'BOYLE:25 92 And that's why -- and he did not want or feel 1 Q. it was appropriate for him to share that with you. And 2 do you understand that? 3 No. 4 A. Okay. You think he should have shared with 5 Q. you? 6 Well, let me just mention parenthetically. 7 A. Putting a question mark on the end of a sentence or a 8 paragraph doesn't make it a question. It's just a 9 statement that you end with an upward inflection in your 10 voice. 11 That's what you say. 12 Q. MR. PRINCIPE: Can you narrow the question? 13 I'm sure that there are a number of English 14 A. teachers that would agree. That was not the discussion 15 that I had with Bill. The e-mail is part of the 16 discussion. We also had in-person discussions both with 17 Bill -- I did with Bill and Denise. 18 My -- the issue for me was not just Thomas & 19 LoCicero. As I've said, Thomas & LoCicero would have 20 always been my first choice. I'm not sure I'm 21 understanding the conflict, though. 22 BY MR. O'BOYLE:23 Okay. That's fine. 24 Q. Help me -- help me -- I'm not trying to be 25 A. 01/26/2016 10:32:45 AM Page 93 to 96 of 135 24 of 44 sheets 93 obtuse. Help me understand the conflict you're talking 1 about. 2 Let's just juvie it. I think we got enough on 3 Q. that. Now, you contacted Sweetapple before he contacted 4 you, correct?5 Yeah. He never -- to the best of my 6 A. recollection, Bob Sweetapple never made any effort to 7 reach out to me. I reached out to him. 8 And when you contacted him, it was to destroy 9 Q. the people in my office, including me? 10 MR. PRINCIPE: Objection; it's not relevant to 11 the bankruptcy. 12 MR. O'BOYLE: It's quite relevant. 13 BY MR. O'BOYLE:14 And you may answer. 15 Q. No. 16 A. "No" what? 17 Q. No. No is the answer to your question. 18 A. Okay. So you did not want to destroy anyone in 19 Q. my office? 20 No. 21 A. Including me? 22 Q. No. 23 A. I see. Then why did you do what you did? You 24 Q. went to as many newspapers as you can go to; am I correct 25 94 there? 1 Gosh, I don't know how many newspapers in the 2 A. world, I don't know. I didn't go to every newspaper that 3 I could have gone to, I don't think. In fact, I don't 4 recall actually going to any newspapers. 5 Okay. 6 Q. You mean did I contact some newspapers, people 7 A. in the media? 8 Yeah, same -- same -- same -- same, yeah. 9 Q. Yeah, I did. Yes, I contacted a number of 10 A. reporters, newspaper editors that I know, yeah, and then 11 I distributed a press release. 12 What was the purpose? 13 Q. To make clear that I was no longer affiliated 14 A. with Citizens Awareness Foundation. 15 And the newspaper articles -- 16 Q. MR. PRINCIPE: Can you give me some dates; 17 narrow the dates down? 18 MR. O'BOYLE: Joel is very familiar with them, 19 but I would say, if I had to, between June of '14 or 20 July of '14 and July of '15. That's what I would 21 say. 22 MR. PRINCIPE: Are you asking the question on 23 behalf of CAFI or are you asking the question on 24 behalf of you individually because you say "we"? 25 95 MR. O'BOYLE: Okay. I'm sorry, I have a habit 1 of saying "we." I'm asking the question.2 MR. PRINCIPE: Well, I'm asking if you can 3 clarify it, unless you can answer it. 4 You're asking me why I sent that out. I sent 5 A. it out because you threatened me. 6 BY MR. O'BOYLE:7 Uh-huh. 8 Q. I actually had -- when I made the decision to 9 A. resign, which I provided a written warning to the board 10 about that. As well as verbally warning them about it, I 11 prepared a pretty moderately-tone press release saying 12 that I had separated from Citizens Awareness Foundation 13 for unresolved, irreconcilable, ethical, and 14 philosophical differences; I think something to that 15 effect. 16 That was all I had intended to do. And then 17 the afternoon or the day that I resigned, which I think 18 was June 30th, you called me, Denise Demartini was on the 19 phone, Bill Ring was on the phone, and you told me -- you 20 said repeatedly that you were going to bring great 21 unpleasantness to my life, presumably this -- what we're 22 doing right now -- was part of that if I did not retract 23 or resend an e-mail exchange that I had had with Nick 24 Taylor. 25 96 And just so you remember, Nick Taylor is the 1 attorney that in my presence and in the presence of 2 someone else in your office you said "Nick Taylor, he's a 3 nigger." That's the one I'm talking about. 4 I said that? 5 Q. You said that, sir. You most certainly did. 6 A. You most certainly did. 7 Okay. 8 Q. That attorney. You wanted me to withdraw an 9 A. e-mail exchange that I had with Nick Taylor. 10 Why? 11 Q. And I refused to do it, and you repeatedly said 12 A. that if I didn't withdraw or retract that e-mail exchange 13 with Nick Taylor that you were going to bring great 14 unpleasantness. 15 Why would I want to threaten you to withdraw an 16 Q. e-mail against someone that I referred to as a nigger? 17 Marty, I can't begin -- 18 A. Does it make sense to you? 19 Q. Much of what you do doesn't make sense, 20 A. including what we're doing here today makes no sense. 21 Okay. That's fine. 22 Q. Why you would want to depose me; why you would 23 A. want me to talk on the record about my relationship with 24 you or Citizens Awareness Foundation or your son, I don't 25 25 of 44 sheets Page 97 to 100 of 135 01/26/2016 10:32:45 AM 97 know why you would want that. I'm happy to accommodate, 1 but -- 2 MR. PRINCIPE: Well, you have to. You're 3 under -- 4 THE DEPONENT: Yeah. Absolutely. I'm happy to 5 accommodate. 6 MR. O'BOYLE: I'm going to ask you to mark 7 these one at a time. There's probably 25 to 30 of 8 them there.9 (Composite Exhibit 6 marked for 10 identification.) 11 BY MR. O'BOYLE:12 I'm asking the court reporter now to mark all 13 Q. of the newspaper articles, which for lack of a better way 14 of saying it, trashed my son and trashed me and emanated 15 from you. 16 Seriously, Marty, if you're going to testify 17 A. you got to be under oath. 18 Okay. 19 Q. I mean, you're testifying. You're doing it 20 A. repeatedly. Can we put him under oath? Do you want to 21 say that again under oath? 22 You're welcome to depose me anytime you want. 23 Q. By the way, the deposition works is you ask the 24 A. questions. You don't get to make statements, and you're 25 98 just making statements. 1 Okay. 2 Q. And I'm objecting to you making statements. 3 A. Ask questions. 4 You've made it clear. From now on when I make 5 Q. a statement, if you would just do this, Mr. Chandler, 6 I'll know exactly what you mean. We'll save a bunch of 7 time. 8 Well, we'd save even more time if you quit 9 A. making statements and ask questions. 10 Okay. 11 Q. MR. PRINCIPE: Can I see the -- 12 MR. O'BOYLE: Yes, you may, Frank. 13 MR. PRINCIPE: May I --14 BY MR. O'BOYLE:15 Anyway, those newspaper articles, they emanated 16 Q. from you, didn't they? 17 MR. PRINCIPE: Look at them first. 18 Well, I'm not a newspaper reporter, so they 19 A. couldn't have. 20 MR. PRINCIPE: I think you ought to look at 21 them to make sure you're testifying correctly. 22 BY MR. O'BOYLE:23 Did you ever have any newspaper articles about 24 Q. me or my son on your website? 25 99 I -- from time to time I have linked various 1 A. articles relating to open government issues on my 2 website, yes. And off the top of my head I couldn't tell 3 you which ones, because there are a lot. 4 If I -- if I told you that you had six articles 5 Q. on your website, which I would use the term "trashed" me 6 and my son, would you say that I'm lying? 7 MR. PRINCIPE: Give me your definition of 8 "trash." 9 MR. O'BOYLE: Trash; saying you're a bad guy; 10 saying that you're a crook; saying not nice things, 11 Frank. 12 MR. PRINCIPE: You can answer that question. 13 I don't remember using the word "crook." I 14 A. don't remember using the "trash." I don't remember -- I 15 don't remember -- you're asking me under oath to say did 16 I say something, and you're using words that I don't 17 think I used. 18 BY MR. O'BOYLE:19 Okay. That's fine. Did you at any time have 20 Q. six articles wherein my son's name and your -- and my 21 name were mentioned and they were on your website? 22 I don't know. 23 A. Okay. Five? 24 Q. I don't know. 25 A. 100 Four. 1 Q. I don't know.2 A. Three?3 Q. I don't know. 4 A. MR. PRINCIPE: Do you have the six articles 5 that maybe he could look at them and then he could 6 answer them? 7 MR. O'BOYLE: He pulled them off of his website 8 I guess in anticipation of this deposition. 9 MR. PRINCIPE: I object to that. I mean, 10 you're speculating. 11 I don't think I've taken anything down off the 12 A. website. 13 BY MR. O'BOYLE:14 They're down off the website. 15 Q. MR. PRINCIPE: Answer the question. 16 BY MR. O'BOYLE:17 They're down off the website; and, of course -- 18 Q. have you made changes to the website recently? 19 Define "recently." 20 A. Last six months. 21 Q. I couldn't say with certainty. It's been I 22 A. think many months since I've done anything on it. 23 Okay. Do you know Ryan Witmer? 24 Q. I do. 25 A. 01/26/2016 10:32:45 AM Page 101 to 104 of 135 26 of 44 sheets 101 How do you know him? 1 Q. I first met him at your office at Commerce 2 A. Group. I can't remember when it was. I seems like it 3 was maybe 2013; delightful guy, very sweet. 4 But yet you knowingly or unknowingly in 5 Q. connection with your relationship with the town of 6 Gulfstream, you have prevented Ryan Witmer from becoming 7 a member of the Bar -- 8 MR. PRINCIPE: Objection to the question. 9 BY MR. O'BOYLE:10 Were you aware that, please, Mr. -- 11 Q. No. I'm not aware of any of that. 12 A. You're not aware of any of that? 13 Q. (Witness shaking head.) 14 A. Were you aware there was a RICO suit filed?15 Q. I imagine that a lot of RICO suits get filed. 16 A. Well, you imagine there was a RICO suit -- did 17 Q. you know there was a RICO suit filed by the Town of 18 Gulfstream against myself and 14 others? 19 I wasn't aware of all of the defendants. I 20 A. know that there was a -- I believe there was a RICO case. 21 I think it was dismissed by the federal court, but 22 imprudently in my opinion I understand it's being 23 appealed. 24 And when you say "imprudently" in your opinion, 25 Q. 102 did you offer that opinion to anyone? 1 I've offered that opinion to a whole bunch of 2 A. people. 3 Uh-huh. Now, Ryan Witmer, he used to do -- 4 Q. what do you call -- record cases. Are you aware of that? 5 You mean public records lawsuits? 6 A. Yeah. I'm sorry. Yes. 7 Q. Yeah. 8 A. Okay. And Ryan, if he were here, he would say 9 Q. that he had a good relationship with you, that you 10 supplied him the templates and -- 11 MR. PRINCIPE: Objection to the line of 12 questioning. There's no question you're making 13 statements. 14 MR. O'BOYLE: No. I'm making a question. 15 MR. PRINCIPE: No. Ask him a specific 16 question. Don't answer it, until he's asked you a 17 question. 18 MR. O'BOYLE: Okay. Can you read back? 19 THE COURT REPORTER: The last question?20 MR. O'BOYLE: Yeah, last question, please. And 21 when you get to the point where Mr. Principe rudely 22 interrupts, just stop and I'll finish it. 23 (The preceding question was read by the court 24 reporter.) 25 103 MR. PRINCIPE: No. It's the next one down; the 1 next question. 2 (The preceding question was read by the court 3 reporter.) 4 MR. O'BOYLE: Okay. 5 MR. PRINCIPE: There's another question. 6 (The preceding question was read by the court 7 reporter.) 8 MR. PRINCIPE: That's when I objected because 9 it's not a question.10 MR. O'BOYLE: I wasn't finished; that's why. 11 BY MR. O'BOYLE:12 That you supplied him templates -- and these 13 Q. are my words -- but a basket of cases I guess for him to 14 go to court, if he had to go to court; is that correct? 15 I have no idea what Ryan would say if he were 16 A. here. 17 Pardon? 18 Q. I have no idea what Ryan would say if he were 19 A. here. 20 Well, let's try it a different way. 21 Q. Please. 22 A. Did you give Ryan the templates that he was 23 Q. using? No? 24 What kind of templates? 25 A. 104 The templates for the public records suits. 1 Q. I provided to Ryan -- as I recall, when I first 2 A. met Ryan and Bill Ring at your offices, I think at some 3 point after that meeting I provided to Bill and to Ryan 4 documents that I had used for my own pro se litigation, 5 and then when the -- when CAFI was started and the 6 O'Boyle Law Firm was engaged to represent CAFI in some 7 public records lawsuits, I think I did the same thing 8 again, some updated documents that I had used for my own 9 litigation. And so, yeah, I think that would be a fair 10 statement in that context anyway. 11 And in connection with your timeline here, you 12 Q. make a comment, if I can find it, that is a comment from 13 Barbara Chandler. Do you remember that? 14 I don't know a Barbara Chandler. 15 A. Barbara -- I'm sorry, Barbara Peterson. Does 16 Q. that sound right? 17 MR. PRINCIPE: Do you have a page number he can 18 refer to? 19 MR. O'BOYLE: I do; June 12th.20 MR. PRINCIPE: About halfway in? June 12th. 21 MR. O'BOYLE: And, Frank, don't be such a 22 meanie to me. 23 You're talking about Chandler meets with 24 A. Barbara Peterson June 12, 2014? 25 27 of 44 sheets Page 105 to 108 of 135 01/26/2016 10:32:45 AM 105 THE COURT REPORTER: I'm sorry, can you repeat 1 that? 2 THE DEPONENT: I'm sorry. 3 "Chandler meets with Barbara Peterson June 12, 4 A. 2014. Chandler meets with Barbara Peterson of the 5 Florida First Amendment Foundation and seeks her counsel 6 on his ethical concerns. She echoes Greg Thomas' advice, 7 but adds that to preserve the -- his credibility, 8 Chandler's departure must be very public and that 9 Chandler should tell MEO to go -- quote 'go fuck 10 himself,'" unquote. It's one of the things I love about 11 Barbara. She's so expressive. 12 BY MR. O'BOYLE:13 Now, is that you talking or is that Barbara 14 Q. Peterson? 15 No. Those are the exact words that came out of 16 A. her mouth. We were sitting at the -- I want to say it's 17 called the Intercontinental now. It's used to be the 18 Lincoln; it's that big hotel on Westshore and Kennedy 19 where the Shula's steakhouse is. We were sitting in the 20 bar. She had a meeting; the board of the directors of 21 the First Amendment Foundation. 22 She was in town and so she happened to be in 23 town. It was close by, and I happened to be doing work 24 over here, so I met with her. And when I described what 25 106 was going on with Citizens Awareness Foundation and the 1 O'Boyle Law Firm and Marty O'Boyle and Jonathan 2 O'Boyle, she had the same response that a number of other 3 attorneys had, which was "why are you still there, you 4 need to leave." She was concerned about making sure that 5 my departure was public; not necessarily explosive. And 6 that's the reason that prior to my resignation when I 7 knew that I was going to resign I prepared the press 8 release and had hoped, as I expressed to you on the 9 telephone when you called me and threatened me, that that 10 would be the end of it; you go your way, I go mine; no 11 hard feelings. It just didn't work out.12 But when you started saying to me -- and you 13 said it repeatedly -- that if I didn't retract or resend 14 the e-mail, which I don't really understand how you would 15 do that -- 16 THE COURT REPORTER: I'm sorry? 17 THE DEPONENT: I'm sorry.18 (The preceding question was read by the court 19 reporter.) 20 The e-mail that I exchanged with Nick Taylor 21 A. just before my resignation -- I think it was the Thursday 22 prior to my resignation -- on a Monday -- that's what 23 precipitated me contacting not only Bob Sweetapple, but a 24 number of other attorneys who were representing 25 107 defendants who were being sued by CAFI.1 BY MR. O'BOYLE: 2 Okay. And your counsel has a -- and I don't 3 Q. know that I have another one, but your counsel has the 4 transcript from when you met with Bob Sweetapple. Do you 5 remember that? 6 The meeting? You mean do I remember the 7 A. meeting with Bob Sweetapple? 8 Yeah. 9 Q. Yes. I remember the meeting. 10 A. Okay. Now -- and also you did an affidavit? 11 Q. I believe that I did. 12 A. MR. O'BOYLE: Do we have that marked? 13 THE COURT REPORTER: We have 3, 4; then the 14 newspaper -- 15 (Exhibits 3 and 4 marked for identification.) 16 MR. PRINCIPE: Right now I object to that being 17 offered into evidence. I don't think it pertains to 18 a 2004 exam.19 THE COURT REPORTER: I'll mark it 5. Did you 20 want to -- you said you wanted the newspaper ones 21 marked individually?22 (Exhibit 5 marked for identification.)23 MR. O'BOYLE: Yeah. But I don't think we're 24 going to go into them. 25 108 BY MR. O'BOYLE:1 Okay. So when we get back to the timeline you 2 Q. said Barbara Peterson told you to "tell Marty O'Boyle to 3 go fuck himself"? 4 Yes. 5 A. Okay. Now, are you sure about that being true 6 Q. as you are with this sworn statement that you did for Bob 7 Sweetapple on July 23rd and the affidavit that you did on 8 October 27, 2014? Are you sure that Barbara Peterson's 9 statement is -- are you sure that -- that -- that these 10 two documents -- 11 MR. PRINCIPE: What are the documents, so we're 12 clear? 13 MR. O'BOYLE: I'm sorry, Frank. This is -- is 14 this Exhibit 5, yeah. 15 BY MR. O'BOYLE:16 Exhibit 5 and Exhibit 4. Are you sure that 17 Q. they are true and correct as you are that Barbara 18 Peterson's statement is true and correct from the 19 timeline? 20 I'd have to read through this again. I mean, 21 A. if you want me to I will.22 Well, you want to take it home? 23 Q. MR. PRINCIPE: Yeah. Why not? 24 No. I don't want to take it home. I got other 25 A. 01/26/2016 10:32:45 AM Page 109 to 112 of 135 28 of 44 sheets 109 things to do with my life. 1 MR. PRINCIPE: All right. 2 I'm a little -- did Barbara Peterson say to me 3 A. "tell Marty to go fuck himself," yes, she said that. Was 4 it verbatim that? I believe that it was. Was it "tell 5 him to go fuck himself" or "tell Marty O'Boyle to go fuck 6 himself" or "tell Marty to go fuck himself" -- 7 THE COURT REPORTER: I'm sorry. Can you slow 8 down? 9 THE DEPONENT: Yeah. Sorry. 10 Was it him; was it Marty O'Boyle; was it Marty; 11 A. was it O'Boyle. I believe she said your full name, as I 12 recall. 13 BY MR. O'BOYLE:14 But generally stated it's true? 15 Q. Yeah. It's true. 16 A. Okay. And my question is, you're saying that 17 Q. that's true. Are you -- when I look at the affidavit and 18 I look at the transcript is -- are they as true as 19 Barbara Peterson's statement? You did them under oath. 20 I believe that my description of the exchange 21 A. of Barbara Peterson is accurate. 22 And? 23 Q. I believe that if I gave a sworn statement, 24 A. that it's accurate. Am I fallible? I suppose it's 25 110 possible. I may have used the wrong verb or I don't 1 know. It's possible that there might be a -- what might 2 otherwise be referred to as a scriveners error, but do I 3 believe that -- that what I said is true and accurate, 4 yes. Do I believe that's the same, as far as an 5 affidavit that I put my hand to, yes. 6 Okay. So generally stated what I think I hear 7 Q. you saying -- and you'll answer me yes or no -- is that 8 you can rely on my timeline that makes the statement 9 about Barbara Peterson saying for Marty O'Boyle -- or 10 some derivative of that, Marty, him, whatever -- to go 11 fuck himself, you can rely on that being true the same as 12 you can rely on the affidavit and on the transcript? 13 No. I cannot rely on your timeline. As I've 14 A. said, I cannot authenticate this. 15 I'm not asking the timeline. 16 Q. You said is it -- you referred to the timeline 17 A. just now. 18 I referred to Barbara Peterson. 19 Q. From the timeline.20 A. Right. 21 Q. And what I'm saying is I cannot confirm the 22 A. veracity of what you have presented as an exhibit because 23 I have not authenticated it against the original that I 24 know that I created. It looks familiar to me. I'm not 25 111 saying it's not the same thing. I'm saying that I can't 1 authenticate it. 2 I understand. Did Barbara Peterson say "tell 3 Q. Marty O'Boyle to go fuck himself"? 4 Yes. 5 A. Okay. And are you sure about that as you are 6 Q. that the content of the transcript and the affidavit are 7 true and correct?8 Well, it's the -- your -- the "as sure" 9 A. language is troubling and I feel it is somewhat unclear. 10 You've asked me under oath if my recollection is that 11 Barbara Peterson uttered those words, and I said yes, 12 something to that effect. 13 Right. You sure did. 14 Q. You've asked me if when I put my hand in an 15 A. affidavit, assuming this is a true copy -- I don't know 16 if it is -- if I put my hand on an affidavit that I 17 believe that it was true, yes. If I put myself under -- 18 if I was under oath for a sworn statement, I believe that 19 my utterances were true. So the whole "as thing" I don't 20 know it's true, it's true, it's true. What Barbara said, 21 yes, she said that. 22 Okay. I think that's fine. Let me ask you a 23 Q. few questions about this affidavit. "Simply put, CAFI is 24 a profit-generating scheme funded by Martin O'Boyle, 25 112 produced to use for his son's legal practice." Where's 1 that come from? 2 I think the facts, sadly. 3 A. "Profit-generating scheme." Where did that 4 Q. come from? 5 All right. Again, I think we really need to 6 A. object to the line of questioning because I feel like 7 we've been accommodating. I've answered a lot of 8 questions today and very, very, very few, if any, have 9 anything to do with my finances or the truthfulness of my 10 statement to the court. 11 As far as the bankruptcy's concerned, I'm happy 12 to answer questions about -- let me finish -- in response 13 to your question. I'm happy to answer questions, be 14 accommodating, provide documents relating to my 15 bankruptcy, relating to all my finances, but we're 16 talking about things that are so -- the only way that 17 there's even a remote connection is the fact that CAFI is 18 suing me, but they're a creditor. That lawsuit has been 19 stayed and the 2004 examination is not intended to be 20 used to gain an unfair advantage in an adversarial 21 proceeding outside of the bankruptcy. It's intended to 22 be used by creditors to try to discover hidden assets. 23 I'm an open book. I don't have any assets to hide. 24 You may answer. 25 Q. 29 of 44 sheets Page 113 to 116 of 135 01/26/2016 10:32:45 AM 113 I'm answering your question. 1 A. MR. PRINCIPE: And we're objecting. We're 2 objecting. 3 And I'm objecting to that. 4 A. BY MR. O'BOYLE:5 Okay. 6 Q. MR. PRINCIPE: Do you want to answer it or not?7 THE DEPONENT: No. Frank, look, I feel like 8 we're done here. 9 MR. O'BOYLE: When you say, Frank, that -- this 10 is a question directly on CAFI and you're 11 instructing him not to answer? 12 MR. PRINCIPE: I think he can answer that, if 13 it's directly on CAFI. 14 BY MR. O'BOYLE:15 Paragraph 66. "Simply put, CAFI is a 16 Q. profit-generating scheme." 17 CAFI was -- 18 A. Let's just answer. Let's keep it short. Let's 19 Q. not make speeches. 20 Ask your question again. 21 A. Paragraph 66 says "Simply put, CAFI is a 22 Q. profit-generating scheme."23 MR. PRINCIPE: Where's that at? 24 MR. O'BOYLE: In the affidavit, Frank. I may 25 114 even have another one, but I don't know. 1 Okay. 2 A. BY MR. O'BOYLE:3 Okay. "Funded by Martin O'Boyle to produce 4 Q. fees for his son's legal practice." 5 Yes. 6 A. Okay. 7 Q. I stand by that. 8 A. Okay. And give me the factual basis. 9 Q. The factual basis is laid out in my motion to 10 A. dismiss. It's laid out in the sworn statement. 11 Let's -- I'm asking you. I'm not -- 12 Q. Can I finish my -- 13 A. Sure. 14 Q. If you ask me a question, you're going to have 15 A. to let me finish them. 16 Sure. Go ahead. 17 Q. I think the ultimate facts of CAFI and the 18 A. O'Boyle Law Firm are sadly that Citizens Awareness 19 Foundation was not created to be an advocacy organization 20 for the rights of citizens in Florida to have greater 21 access to public records and open meetings. I think that 22 ultimately the chief ambition was to generate lawsuits, 23 all of which were channelled to your son's law firm, 24 which you financed. 25 115 You financed both your son's law firm and your 1 long-time employee, Denise Demartini, had managerial 2 control of that law firm, in spite of the fact that she 3 was not a licensed attorney in Florida. You also funded 4 Citizens Awareness Foundation. Your proxy, Denise 5 Demartini, in writing demanded that I produce at least 25 6 lawsuits per week. She demanded that I draft lawsuits.7 It was clear that the ambition all that 8 mattered was let's see how many lawsuits we can file, and 9 then on top of filing lawsuit after lawsuit after 10 lawsuit -- and the lawsuits that I referred to the 11 foundation, the facts were good, no question in my mind 12 that they were real violations of Public Records Act, but 13 one of the ultimate concerns and I think validations of 14 my statement that it was nothing more than a 15 revenue-generating scheme is the fact that the law firm 16 kept demanding settlement amounts that were far beyond 17 the actual fees that they earned. And that was the 18 e-mail exchange that I had with Nick Taylor where I 19 challenged him on that issue. 20 I had challenged the board on this repeatedly; 21 and in fact immediately after my meeting with Barbara 22 Peterson while I was still in the hotel parking garage, I 23 got a phone call. And it was Denise, John -- Denise 24 Demartini, Bill Ring, and Jonathan O'Boyle were on the 25 116 phone and I was still on the phone with them, on the same 1 telephone call by the time I got back -- all the way back 2 to Lakeland. And I was as blunt, direct, undiplomatic, 3 crass, vulgar as I could be in explaining to them my 4 absolute objection to the law firm making demands for 5 payment beyond the actual fees and costs that they had 6 earned and accrued. 7 And you're talking about -- 8 Q. Let me finish my questions. 9 A. Your question. 10 Q. I answered your question. 11 A. Okay. 12 Q. I was as vociferous and blunt as I could be in 13 A. explaining that position that I was adamantly opposed to 14 it, that I wouldn't agree to it, that I wouldn't be 15 associated with the organizations if this continued. And 16 yet I got a phone call the following day, two phone 17 calls -- one from one person at the law firm and another 18 from another person at the law firm telling me that 19 Denise, Jonathan, and Bill had gone in the very next day 20 and that Joel approved of the program, because the other 21 attorneys knew that I didn't, because I had been 22 apoplectic with them about my objections to it. 23 And I think that the fact that no lawsuits 24 could be filed with any other law firm, that there was a 25 01/26/2016 10:32:45 AM Page 117 to 120 of 135 30 of 44 sheets 117 quota that was imposed upon me to produce 25 lawsuits per 1 week -- which is I think is beyond disputed because 2 there's an e-mail exchange that I have with Denise where 3 she says that -- and the fact that the law firm was 4 repeatedly demanding fees and costs far beyond what had 5 actually been accrued I think evidenced my statement that 6 it was nothing more than a review-generating scheme. And 7 I'm all for people making money and I'm all for the 8 attorneys getting paid. 9 I think you're far beyond the question, but I 10 Q. appreciate that answer. 11 So I can't say any more. You cut me off. 12 A. No, I think it's time. I think you've answered 13 Q. long enough. 14 You asked me an open-ended question. I tried 15 A. to answer it. 16 I understand. I appreciate it. 17 Q. MR. DESOUZA: What was the question? I heard 18 the answer, but I didn't hear the question. 19 MR. O'BOYLE: We're not going there. I'll play 20 it for you tonight. 21 THE DEPONENT: He was asking me from page 10 of 22 the affidavit, number 66. "Simply put, CAFI is a 23 profit-generating scheme funded by Martin O'Boyle to 24 produce fees for his son's legal practice." He 25 118 asked me what facts there were to support that.1 There are a lot of other facts, but you cut me 2 A. off. 3 BY MR. O'BOYLE: 4 Okay. Good. 5 Q. So I guess we're done with questions, since 6 A. you're cutting me off and not letting me answer them in 7 full. You asked me what facts there are. There are 8 more, which I'll be more than happy to continue to put on 9 the record, but you're not going to let me. 10 Go ahead. Put them on the record. Make 11 Q. yourself happy. 12 What time are we stopping? 13 A. 6:00. 14 Q. MR. PRINCIPE: No, we said 5:00. 15 MR. O'BOYLE: We didn't anticipate a 16 filibuster. 17 THE DEPONENT: Marty, you're the one who's 18 filibustered. You've gone and made statements. You 19 asked me questions. You cut me off. Don't accuse 20 me of filibustering. You asked me a question; I 21 answered. You're the one who made statements 22 without being under oath. 23 MR. O'BOYLE: You can answer that question then 24 tomorrow. 25 119 MR. PRINCIPE: We're going to take hers 1 tomorrow morning? 2 MR. DESOUZA: Marty, let me finish. 3 MR. O'BOYLE: Go ahead. 4 THE DEPONENT: No. I'm done. You cut me off. 5 I'm done. I'm done. 6 MR. PRINCIPE: You can ask that question again 7 tomorrow, if you want. 8 THE DEPONENT: Ask it again tomorrow. I'll be 9 more than happy to say it again tomorrow. 10 MR. O'BOYLE: Well, I'm going to ask questions, 11 and if you want to answer your question we said you 12 can. So continue on.13 THE DEPONENT: You cut me off. Do you want to 14 ask again tomorrow? Look, it's 5:00. 15 MR. O'BOYLE: I apologize. I apologize. 16 THE DEPONENT: Marty, it's 5:00. You want to 17 ask it again tomorrow, ask it again tomorrow. 18 MR. DESOUZA: All right. Everyone time-out for 19 a second. Can we go off the record? 20 (Discussion off the record and deposition 21 concluded.)22 23 24 25 120 CERTIFICATE OF OATH1 STATE OF FLORIDA )2 COUNTY OF HILLSBOROUGH ) 3 I, the undersigned authority, certify that 4 JOEL EDWARD CHANDLER personally appeared before me and 5 was duly sworn.6 WITNESS my hand and official seal this 1st 7 day of October, 2015. 8 9 10 11 _______________________________12 VANESSA MENDOZA, FPR 13 Notary Public State of Florida at Large14 My Commission Number: FF078246 Expires: 12/19/201715 16 17 18 19 20 21 22 23 24 25 31 of 44 sheets Page 121 to 122 of 135 01/26/2016 10:32:45 AM 121 CERTIFICATE OF REPORTER1 STATE OF FLORIDA )2 COUNTY OF HILLSBOROUGH ) 3 I, VANESSA MENDOZA, certify that I was 4 authorized to and did stenographically report the 5 foregoing deposition and that the transcript is a true 6 record of the testimony given by the witness.7 I FURTHER CERTIFY that I am not a relative, 8 employee, attorney, or counsel of any of the parties, nor 9 am I a relative or employee of the parties' attorneys or 10 counsel connected with the action, nor am I financially 11 interested in the action.12 13 14 15 16 17 DATED this 22nd day of January 2016. 18 19 20 ____________________________________21 VANESSA MENDOZA, FPR22 Notary Public State of Florida at Large23 My Commission Number: FF078246 Expires: 12/19/201724 25 122 SIGNATURE PAGE/ERRATA SHEET1 WITNESS: JOEL EDWARD CHANDLER2 3 INSTRUCTIONS TO WITNESS 4 After you have read the transcript of your deposition, please note any errors in the transcription 5 on this page. Do not mark on the transcript itself. Please sign and date this page as indicated below. If 6 additional lines are required for corrections, attach additional pages.7 PAGE/LINE ERROR OR AMENDMENT/REASON FOR CHANGE8 ___________________ ____________________________________9 _______________________________________________________ _______________________________________________________10 _______________________________________________ ________ _______________________________________________________11 _______________________________________________________ _______________________________________________________12 __________________ _____________________________________ _______________________________________________________13 _______________________________________________________ _______________________________________________ ________14 _______________________________________________________ _______________________________________________________15 _______________________________________________________ __________________ _____________________________________16 _______________________________________________________ _______________________________________________________ 17 ___________________________________________ ____________ _______________________________________________________18 ____ ____ _____________________________________________ 19 I have read the transcript of my deposition and subscribe 20 to its accuracy, to include the corrections or amendments noted above or attached hereto.21 22 ___________________________________ Signature of witness Date 23 24 25 01/26/2016 10:32:45 AM Page 123 to 123 of 135 32 of 44 sheets ' '14[2] - 94:20, 94:21 '15[1] - 94:21 '88[1] - 81:11 '89[1] - 81:11 'go[1] - 105:10 1 1[6] - 1:11, 4:3, 56:12, 72:4, 72:5, 72:6 1.1[1] - 51:7 1.3[1] - 51:7 10[3] - 9:3, 9:7, 117:22 100[1] - 2:7 101[1] - 2:10 107[3] - 4:5, 4:6, 4:7 10th[1] - 76:8 12[2] - 104:25, 105:4 12/17/14[1] - 38:12 12/19/2017[2] 120:15, 121:24 120[1] - 3:7 121[1] - 3:8 122[1] - 3:9 1280[1] - 2:3 12th[2] - 104:20, 104:21 13[3] - 30:17, 30:18, 30:21 1355[1] - 5:19 14[1] - 101:19 15[1] - 60:2 1500[1] - 2:10 1990[1] - 40:11 1:47[1] - 1:12 1st[1] - 120:7 2 2[4] - 4:4, 51:6, 74:17, 76:15 20[1] - 6:17 200[1] - 82:12 2004[20] - 5:12, 10:15, 11:21, 14:9, 16:21, 22:22, 22:25, 23:2, 23:5, 29:13, 29:16, 45:16, 48:17, 49:15, 74:6, 74:7, 76:4, 78:7, 107:19, 112:20 2013[1] - 101:4 2014[10] - 66:22, 67:12, 67:16, 76:10, 76:15, 84:8, 91:15, 104:25, 105:5, 108:9 2015[2] - 1:11, 120:8 2016[1] - 121:18 21[1] - 43:8 22nd[1] - 121:18 23rd[1] - 108:8 24[1] - 36:13 25[4] - 36:8, 97:8, 115:6, 117:1 27[2] - 67:12, 108:9 2805[1] - 2:7 2:03[1] - 15:6 2:08[1] - 15:6 2:48[1] - 48:13 2nd[4] - 76:13, 78:23, 78:25, 84:21 3 3[4] - 4:5, 48:13, 107:14, 107:16 30[1] - 97:8 30th[2] - 67:16, 95:19 33301[1] - 2:10 33442[1] - 2:4 33602[1] - 1:14 33618[1] - 2:7 33803[1] - 5:20 34[2] - 64:17, 64:20 36[1] - 57:12 37[3] - 11:18, 22:25, 64:18 3:12[1] - 59:8 3:21[1] - 59:8 3:53[1] - 74:18 3rd[1] - 2:10 4 4[5] - 4:6, 76:12, 107:14, 107:16, 108:17 400[1] - 1:14 403[1] - 1:13 47[3] - 36:8, 60:2, 64:18 4:01[1] - 74:18 4:52[1] - 76:15 4th[5] - 76:18, 78:19, 84:8, 84:14, 91:15 5 5[7] - 1:12, 3:4, 4:7, 107:20, 107:23, 108:15, 108:17 50[10] - 5:24, 6:2, 6:5, 6:11, 6:15, 6:16, 6:25, 34:8, 66:2 501[1] - 83:2 5:00[3] - 118:15, 119:15, 119:17 6 6[2] - 4:8, 97:10 60[1] - 17:17 66[3] - 113:16, 113:22, 117:23 6:00[1] - 118:14 7 7[10] - 1:6, 38:14, 43:10, 53:24, 54:1, 54:3, 54:12, 54:14, 56:13, 56:14 72[1] - 4:3 74[1] - 4:4 75[1] - 17:17 8 8:14-bk-142230-KRM [1] - 1:5 8:14-bravo-kilo14223-kilo-romeomike[1 ] - 5:16 9 9[1] - 9:3 90[1] - 8:6 95[1] - 17:17 97[1] - 4:8 A abbreviate[1] - 65:1 ability[4] - 14:20, 41:8, 55:13, 59:2 able[2] - 52:19, 58:15 absolute[1] - 116:5 absolutely[1] - 97:5 accept[4] - 8:9, 8:13, 8:21, 44:4 access[5] - 55:21, 55:22, 55:23, 59:1, 114:22 accessible[2] - 56:22, 57:5 accommodate[3] 58:21, 97:1, 97:6 accommodated[1] 8:7 accommodating[2] 112:8, 112:15 accommodations[1] - 57:3 accomodation[2] 55:25, 56:7 according[1] - 20:7 accrued[2] - 116:7, 117:6 accuracy[1] - 122:20 accurate[14] - 68:17, 68:19, 68:22, 68:23, 68:25, 69:3, 69:4, 69:5, 69:9, 69:13, 87:16, 109:22, 109:25, 110:4 accuse[1] - 118:20 Act[1] - 115:13 acting[3] - 62:23, 63:1, 63:6 action[3] - 36:23, 121:11, 121:12 activism[1] - 88:13 acts[2] - 41:3, 41:4 actual[2] - 115:18, 116:6 adamantly[1] 116:14 add[1] - 84:7 added[1] - 82:6 addition[2] - 35:2, 35:4 additional[4] - 51:16, 51:17, 122:6, 122:7 address[2] - 5:17, 26:6 adds[1] - 105:8 adjourn[1] - 23:8 adjustment[1] - 9:1 adoption[1] - 81:5 advantage[3] - 10:16, 45:18, 112:21 adversarial[5] 10:16, 45:17, 82:4, 90:13, 112:21 adversary[2] - 90:13, 90:20 adverse[3] - 91:5, 91:7, 91:8 advice[1] - 105:7 advises[2] - 15:1 advocacy[1] - 114:20 affidavit[11] - 107:11, 108:8, 109:18, 110:6, 110:13, 111:7, 111:16, 111:17, 111:24, 113:25, 117:23 affiliated[1] - 94:14 affirm[1] - 5:1 affy[1] - 75:7 afternoon[2] - 90:16, 95:18 ago[4] - 19:5, 86:15, 88:3, 88:7 123 agree[11] - 29:17, 40:16, 45:15, 59:13, 61:17, 62:19, 70:4, 73:8, 87:11, 92:15, 116:15 agreed[4] - 30:23, 68:5, 68:6, 68:10 agreed-upon[1] 30:23 agreement[1] - 67:20 ahead[10] - 27:23, 29:2, 36:10, 48:5, 72:18, 72:19, 80:16, 114:17, 118:11, 119:4 airplane[1] - 16:10 alleged[1] - 27:18 allow[2] - 29:25, 48:24 almost[1] - 51:6 ambition[2] - 114:23, 115:8 Amendment[2] 105:6, 105:22 AMENDMENT/ REASON[1] - 122:8 amendments[1] 122:21 amounts[1] - 115:17 Ana[3] - 47:5, 47:6, 47:7 Anderson[2] - 47:5, 47:7 Andrew[1] - 84:4 answer[74] - 6:13, 10:13, 10:20, 10:23, 10:25, 11:5, 11:11, 12:24, 13:10, 13:13, 13:17, 14:10, 14:17, 14:19, 14:22, 15:1, 15:11, 15:18, 17:1, 17:13, 18:15, 19:19, 19:20, 20:24, 21:3, 23:24, 23:25, 25:17, 26:1, 26:3, 27:1, 27:21, 28:15, 28:22, 29:1, 29:23, 30:20, 31:22, 32:21, 34:22, 35:16, 36:19, 40:17, 40:18, 41:20, 44:4, 46:10, 46:23, 50:14, 52:17, 58:15, 79:18, 93:15, 93:18, 95:4, 99:13, 100:7, 100:16, 102:17, 110:8, 112:13, 112:14, 112:25, 113:7, 113:12, 113:13, 113:19, 117:11, 117:16, 117:19, 118:7, 118:24, 119:12 33 of 44 sheets Page 124 to 124 of 135 01/26/2016 10:32:45 AM answered[23] - 6:3, 20:23, 20:25, 21:1, 28:12, 30:4, 32:1, 32:14, 32:15, 34:10, 34:18, 40:2, 43:3, 43:5, 44:3, 47:10, 48:6, 64:8, 64:22, 112:8, 116:11, 117:13, 118:22 answering[3] - 29:12, 45:9, 113:1 answers[4] - 18:23, 31:25, 35:11, 65:23 anticipate[1] - 118:16 anticipated[1] - 71:19 anticipation[1] 100:9 anytime[1] - 97:23 anyway[2] - 98:16, 104:11 apartment[1] - 25:10 apologize[2] - 119:16 apoplectic[1] 116:23 appealed[1] - 101:24 appear[2] - 85:4, 87:23 appearance[4] - 80:6, 83:25, 88:9, 89:5 APPEARANCES[1] 2:1 appeared[2] - 78:4, 120:5 Appearing[1] - 2:2 appellate[2] - 82:8, 86:15 appended[1] - 52:4 Apple[2] - 52:6, 55:22 appreciate[2] 117:11, 117:17 appropriate[1] - 92:2 approved[1] - 116:21 arbiter[1] - 13:3 argue[3] - 35:5, 57:19 argued[2] - 82:9, 85:20 arguing[1] - 83:24 argument[2] - 83:6, 83:22 arrangements[1] 8:5 arrears[1] - 8:6 arrested[1] - 40:8 articles[8] - 94:16, 97:14, 98:16, 98:24, 99:2, 99:5, 99:21, 100:5 assert[2] - 33:21, 39:4 asserting[1] - 39:9 assertions[1] - 39:5 assets[2] - 112:23, 112:24 associated[1] 116:16 assume[3] - 12:14, 48:17, 52:16 assuming[2] - 52:14, 111:16 Atlantic[3] - 90:2, 90:9, 91:1 attach[1] - 122:6 attached[1] - 122:21 attempting[3] - 10:15, 13:20, 14:11 attested[1] - 64:21 attorney[9] - 39:2, 42:12, 42:13, 48:17, 86:24, 96:2, 96:9, 115:4, 121:9 attorney's[1] - 54:5 attorneys[9] - 30:14, 46:16, 81:23, 85:16, 106:4, 106:25, 116:22, 117:9, 121:10 authenticate[2] 110:15, 111:2 authenticated[1] 110:24 authenticating[2] 75:19, 76:14 authority[1] - 120:4 authorize[3] - 79:7, 79:15, 85:11 authorized[1] - 121:5 Avenue[1] - 2:10 avoid[2] - 66:3, 80:6 aware[15] - 23:6, 36:5, 36:19, 37:3, 37:6, 37:19, 37:20, 42:16, 43:16, 101:11, 101:12, 101:13, 101:15, 101:20, 102:5 Awareness[13] 30:22, 44:19, 45:6, 60:5, 66:9, 66:21, 67:2, 94:15, 95:13, 96:25, 106:1, 114:19, 115:5 B bad[5] - 38:25, 40:25, 41:9, 89:11, 99:10 bankruptcy[44] 5:13, 10:5, 10:8, 10:17, 11:1, 11:18, 12:5, 12:6, 12:8, 12:16, 12:23, 13:18, 14:10, 17:11, 18:7, 18:9, 18:18, 23:9, 23:12, 24:10, 24:12, 25:25, 27:12, 30:6, 30:7, 30:8, 36:18, 41:16, 42:12, 42:17, 42:21, 44:23, 44:25, 45:8, 45:11, 45:14, 45:16, 59:22, 61:20, 63:11, 74:12, 93:12, 112:16, 112:22 BANKRUPTCY [1] 1:1 bankruptcy's[1] 112:12 Bar[1] - 101:8 bar[1] - 105:21 Barbara[21] - 104:14, 104:15, 104:16, 104:25, 105:4, 105:5, 105:12, 105:14, 108:3, 108:9, 108:18, 109:3, 109:20, 109:22, 110:10, 110:19, 111:3, 111:12, 111:21, 115:22 Barnes[8] - 80:21, 81:2, 81:10, 85:12, 85:14, 86:10, 86:11 based[3] - 45:7, 66:24, 79:16 basis[4] - 60:10, 60:13, 114:9, 114:10 basket[1] - 103:14 Beach[3] - 2:4, 43:13, 66:24 bear[2] - 63:19, 76:17 bearing[2] - 70:19, 86:9 became[1] - 67:2 becoming[1] - 101:7 begin[3] - 66:17, 70:17, 96:18 beginning[1] - 7:24 beginnings[1] - 82:25 begs[1] - 35:15 behalf[4] - 42:16, 81:14, 94:24, 94:25 belief[1] - 36:15 below[1] - 122:6 bend[1] - 36:25 best[12] - 11:3, 14:20, 36:14, 37:1, 54:7, 55:13, 64:14, 64:17, 74:21, 88:19, 93:6 better[2] - 68:15, 97:14 between[1] - 94:20 beyond[8] - 11:11, 29:16, 63:10, 115:17, 116:6, 117:2, 117:5, 117:10 big[1] - 105:19 Bill[17] - 75:24, 79:2, 83:10, 83:16, 84:24, 87:3, 89:4, 90:4, 91:18, 92:16, 92:18, 95:20, 104:3, 104:4, 115:25, 116:20 bit[1] - 78:25 blunt[2] - 116:3, 116:13 board[8] - 80:11, 83:11, 83:18, 85:10, 88:11, 95:10, 105:21, 115:21 Bob[20] - 11:9, 11:25, 27:5, 71:9, 71:17, 77:18, 82:11, 82:23, 83:3, 85:1, 86:23, 87:5, 87:11, 88:2, 88:4, 93:7, 106:24, 107:5, 107:8, 108:7 book[5] - 10:13, 80:21, 81:2, 81:9, 112:24 books[1] - 81:7 bookstore[3] - 81:6, 85:14 borrow[2] - 60:17, 60:23 Boulevard[1] - 2:7 Boyle[2] - 2:5, 5:11 Boyle's[1] - 50:14 break[1] - 90:17 Brenda[1] - 79:3 briefs[2] - 85:22, 86:6 bring[5] - 49:16, 50:15, 61:9, 95:21, 96:14 broad[3] - 65:20, 65:22, 66:16 broader[1] - 29:15 brother[2] - 81:18, 85:12 Broward[1] - 43:13 bunch[4] - 11:8, 89:22, 98:7, 102:2 Burns[1] - 1:13 Busch[1] - 2:7 BY[101] - 1:16, 5:10, 6:14, 7:15, 10:18, 12:12, 13:1, 14:16, 15:8, 15:15, 15:23, 17:3, 17:12, 18:21, 20:5, 20:19, 21:5, 24:7, 24:23, 25:4, 25:14, 26:2, 26:20, 27:20, 28:3, 28:10, 29:22, 32:6, 32:13, 32:24, 34:20, 36:6, 36:11, 37:16, 38:6, 124 38:17, 39:21, 41:22, 42:25, 43:6, 43:11, 46:4, 46:17, 47:14, 48:9, 48:15, 49:5, 49:10, 49:14, 50:18, 51:25, 52:23, 53:15, 54:11, 54:20, 56:10, 59:9, 59:20, 60:4, 60:21, 62:25, 63:25, 64:11, 65:12, 65:17, 66:5, 67:17, 69:17, 70:13, 71:4, 72:11, 74:20, 76:7, 77:8, 79:20, 84:1, 86:22, 87:10, 90:8, 91:17, 91:25, 92:23, 93:14, 95:7, 97:12, 98:15, 98:23, 99:19, 100:14, 100:17, 101:10, 103:12, 105:13, 107:2, 108:1, 108:16, 109:14, 113:5, 113:15, 114:3, 118:4 C C3[1] - 83:2 CAFI[58] - 2:9, 11:8, 23:16, 23:18, 27:13, 27:16, 27:19, 33:3, 56:3, 57:2, 62:6, 65:7, 65:9, 65:13, 65:18, 66:4, 66:6, 66:20, 67:18, 67:20, 68:16, 70:1, 70:24, 71:2, 71:6, 71:10, 72:1, 74:8, 74:10, 74:14, 76:11, 76:23, 78:7, 79:7, 79:15, 79:16, 80:4, 82:25, 84:17, 85:12, 91:4, 94:24, 104:6, 104:7, 107:1, 111:24, 112:18, 113:11, 113:14, 113:16, 113:18, 113:22, 114:18, 117:23 CAFI's[2] - 74:5, 74:11 campus[4] - 81:3, 81:9, 81:19, 85:13 cannot[5] - 73:17, 73:20, 110:14, 110:15, 110:22 capable[5] - 41:3, 41:4, 41:10, 41:11, 41:13 car[4] - 16:24, 17:2, 44:8, 44:9 Case[1] - 1:4 01/26/2016 10:32:45 AM Page 125 to 125 of 135 34 of 44 sheets case[30] - 5:15, 23:19, 30:24, 54:1, 54:14, 55:18, 56:14, 61:5, 63:10, 75:25, 80:17, 80:18, 80:19, 80:20, 80:23, 80:25, 81:1, 83:7, 83:8, 85:12, 85:15, 85:17, 86:7, 86:10, 86:12, 86:19, 89:9, 91:4, 101:21 cases[9] - 80:12, 82:8, 83:20, 85:7, 85:21, 86:4, 102:5, 103:14 cash[2] - 8:1, 8:7 causes[1] - 36:23 CC[1] - 79:3 Center[1] - 2:3 certain[3] - 67:12, 70:16, 75:21 certainly[9] - 56:25, 62:14, 62:16, 70:19, 74:2, 75:23, 89:3, 96:6, 96:7 certainty[6] - 47:20, 73:17, 74:24, 75:22, 77:25, 100:22 CERTIFICATE[2] 120:1, 121:1 certificate[1] - 49:7 Certificate[2] - 3:7, 3:8 certify[2] - 120:4, 121:4 CERTIFY[1] - 121:8 challenged[2] 115:20, 115:21 Chandler[27] - 5:11, 5:14, 5:19, 5:21, 15:9, 28:19, 32:4, 36:7, 40:8, 48:10, 48:16, 52:1, 59:21, 64:1, 64:2, 73:25, 76:15, 77:1, 79:2, 98:6, 104:14, 104:15, 104:24, 105:4, 105:5, 105:10 CHANDLER[7] - 1:4, 1:5, 1:9, 3:2, 5:6, 120:5, 122:2 Chandler's[3] - 57:7, 75:25, 105:9 change[2] - 48:24, 56:5 CHANGE[1] - 122:8 changed[2] - 8:3, 73:10 changes[1] - 100:19 changing[1] - 48:21 channelled[1] 114:24 Chapter[11] - 1:6, 30:17, 30:18, 30:21, 38:14, 53:24, 54:1, 54:3, 54:12, 54:14, 56:14 chapter[1] - 56:13 character[8] - 36:25, 40:14, 40:20, 40:22, 40:23, 40:24, 40:25, 41:10 characterization[1] 68:23 characterize[1] 44:23 Charles[1] - 41:7 check[1] - 68:7 chief[1] - 114:23 choice[2] - 86:20, 92:21 chronological[1] 71:15 circulated[1] - 81:6 circus[1] - 11:7 cited[2] - 85:21, 86:6 Citizens[14] - 30:22, 31:1, 44:19, 45:5, 60:5, 66:9, 66:21, 67:2, 94:15, 95:13, 96:25, 106:1, 114:19, 115:5 citizens[1] - 114:21 City[4] - 48:3, 90:2, 90:10, 91:1 Civil[1] - 88:13 civilly[1] - 89:23 claim[13] - 11:9, 31:6, 31:7, 31:10, 33:2, 35:25, 37:12, 37:17, 38:5, 41:23, 43:7, 62:6, 74:11 claiming[1] - 81:12 claims[10] - 23:20, 35:12, 35:18, 36:16, 37:22, 43:2, 43:7, 43:12, 43:21, 59:24 Clara[2] - 47:5, 47:7 clarification[1] 35:22 clarify[1] - 95:4 clear[11] - 11:6, 36:22, 42:11, 55:15, 62:12, 63:5, 91:13, 94:14, 98:5, 108:13, 115:8 close[2] - 39:15, 105:24 Cloud[1] - 48:4 collected[1] - 81:14 college[1] - 80:21 coming[5] - 21:22, 22:11, 22:13, 26:22, 40:6 comment[2] - 104:13 Commerce[2] - 2:3, 101:2 Commission[2] 120:14, 121:23 communications[1] 46:11 compare[5] - 69:20, 69:24, 72:23, 73:4, 73:18 comparing[1] - 75:20 compel[1] - 13:5 compensation[1] 67:10 competitors[1] - 81:9 complete[1] - 70:1 Composite[1] - 97:10 composite[1] - 72:7 compound[4] - 15:17, 25:16, 26:25, 28:2 compromise[1] - 68:5 compromised[4] 68:9, 69:18, 69:19, 69:23 computer[8] - 50:2, 52:5, 52:6, 52:7, 53:6, 53:7, 53:11, 58:20 computers[1] - 50:7 concept[2] - 70:8, 70:9 concern[3] - 45:9, 80:2, 88:25 concerned[4] - 34:22, 41:10, 106:5, 112:12 concerning[1] - 36:9 concerns[3] - 86:17, 105:7, 115:14 concluded[1] 119:22 conclusion[1] - 46:7 conclusions[2] 42:14, 42:20 concrete[1] - 85:6 condition[2] - 10:11, 24:12 conference[3] 82:24, 85:1, 88:1 confident[5] - 33:23, 33:25, 34:2, 34:3, 35:8 confirm[1] - 110:22 conflict[2] - 92:22, 93:1 confused[1] - 22:4 connected[1] 121:11 connection[18] 5:12, 18:4, 18:25, 19:1, 49:11, 53:25, 54:13, 56:14, 59:22, 60:5, 61:5, 71:6, 71:16, 78:7, 101:6, 104:12, 112:18 consensus[1] - 85:8 consideration[1] 87:18 consisting[1] - 36:13 consult[4] - 33:22, 34:16, 35:9, 46:9 consulted[1] - 47:22 contact[1] - 94:7 contacted[6] - 8:2, 46:15, 93:4, 93:9, 94:10 contacting[1] 106:24 contemplating[1] 88:12 content[1] - 111:7 context[5] - 51:14, 65:14, 70:19, 71:14, 104:11 contingency[1] - 86:8 continue[3] - 77:12, 118:9, 119:13 continued[1] - 116:16 contract[1] - 68:4 control[2] - 70:1, 115:3 conversation[9] 42:6, 71:9, 71:19, 79:17, 79:19, 81:23, 82:17, 82:22, 88:8 conversations[10] 14:8, 21:12, 21:15, 21:16, 21:19, 21:21, 71:21, 71:23, 80:10, 83:3 copies[3] - 52:7, 53:19, 81:5 copy[3] - 76:21, 77:24, 111:16 corner[2] - 25:9, 25:18 corporation[2] 66:23, 67:11 correct[42] - 6:20, 6:25, 7:3, 17:6, 20:10, 21:20, 22:6, 22:9, 26:24, 29:5, 30:3, 34:11, 36:14, 37:18, 38:19, 43:22, 44:2, 44:20, 47:15, 48:18, 64:3, 64:12, 64:22, 64:23, 65:1, 65:2, 65:4, 65:5, 67:21, 68:16, 70:5, 73:11, 74:5, 77:24, 84:17, 86:25, 93:5, 93:25, 103:15, 125 108:18, 108:19, 111:8 corrections[2] 122:6, 122:20 correctly[2] - 64:22, 98:22 cost[1] - 89:17 costs[3] - 86:9, 116:6, 117:5 Counsel[2] - 2:6, 2:9 counsel[19] - 13:15, 14:25, 21:2, 46:7, 46:9, 46:12, 46:13, 61:11, 62:18, 62:23, 63:1, 63:6, 105:6, 107:3, 107:4, 121:9, 121:11 counterclaim[1] 44:18 County[1] - 43:13 COUNTY[2] - 120:2, 121:2 couple[1] - 68:8 course[6] - 19:7, 37:20, 46:22, 67:7, 80:15, 100:18 coursework[1] - 81:8 COURT[20] - 1:1, 5:1, 5:5, 19:19, 32:10, 48:14, 51:24, 59:18, 69:14, 79:9, 79:13, 83:12, 83:14, 86:3, 102:20, 105:1, 106:17, 107:14, 107:20, 109:8 court[29] - 15:13, 15:21, 19:25, 20:3, 24:3, 26:12, 26:23, 27:3, 27:4, 28:7, 29:14, 30:24, 32:11, 32:18, 32:22, 42:23, 45:21, 45:24, 69:15, 81:13, 97:13, 101:22, 102:24, 103:3, 103:7, 103:15, 106:19, 112:11 court's[1] - 54:6 cover[1] - 90:1 crass[1] - 116:4 created[9] - 63:9, 66:22, 67:11, 67:14, 75:22, 76:14, 77:19, 110:25, 114:20 creating[1] - 67:4 credibility[3] - 82:7, 84:7, 105:8 creditor[5] - 23:19, 60:7, 60:8, 60:11, 112:19 creditors[3] - 14:21, 35 of 44 sheets Page 126 to 126 of 135 01/26/2016 10:32:45 AM 59:23, 112:23 criminally[1] - 89:24 crook[2] - 99:11, 99:14 current[5] - 7:13, 7:16, 7:19, 30:6 cut[13] - 74:24, 74:25, 75:4, 75:7, 75:11, 75:12, 75:17, 117:12, 118:2, 118:20, 119:5, 119:14 cutting[1] - 118:7 D Daewoo[3] - 44:10, 44:11, 44:13 dan[3] - 50:24, 54:15, 77:1 Dan[3] - 55:2, 57:1, 76:23 DANIEL[1] - 2:9 data[2] - 51:7, 51:8 date[5] - 37:8, 76:6, 78:24, 91:10, 122:6 Date[1] - 122:23 DATE[1] - 1:11 DATED[1] - 121:18 dates[4] - 7:25, 91:11, 94:17, 94:18 days[2] - 8:6, 67:8 DCA[3] - 80:23, 81:12, 86:14 DCF[1] - 86:13 dead[1] - 11:3 deal[2] - 14:12, 14:14 dealing[4] - 80:7, 85:5, 87:24, 88:9 Deborah[1] - 5:14 DEBORAH[1] - 1:5 debt[2] - 27:18 debtor[1] - 60:6 debtor's[3] - 54:1, 54:14, 56:14 debtors[1] - 36:9 Debtors[2] - 1:6, 2:6 December[1] - 40:12 decide[2] - 17:24, 23:1 decided[1] - 13:9 decision[2] - 86:15, 95:9 declaration[1] - 36:8 declare[1] - 36:12 deep[1] - 89:11 deeper[1] - 89:11 Deerfield[2] - 2:4, 66:24 defendants[2] 101:20, 107:1 define[2] - 70:9, 100:20 definition[1] - 99:8 definitive[1] - 79:18 delightful[1] - 101:4 demanded[2] - 115:6, 115:7 demanding[2] 115:17, 117:5 demands[1] - 116:5 Demartini[6] - 83:10, 83:17, 95:19, 115:2, 115:6, 115:25 denied[1] - 75:25 Denise[12] - 79:3, 79:4, 83:10, 83:17, 92:18, 95:19, 115:2, 115:5, 115:24, 116:20, 117:3 deny[1] - 69:25 department[1] - 25:23 departure[2] - 105:9, 106:6 DEPONENT[37] 13:19, 14:1, 14:4, 18:19, 19:21, 20:16, 25:2, 45:14, 46:1, 50:24, 51:12, 51:16, 58:13, 58:19, 58:25, 62:10, 62:14, 72:4, 79:11, 79:15, 83:13, 83:16, 84:18, 85:24, 86:1, 86:5, 97:5, 105:3, 106:18, 109:10, 113:8, 117:22, 118:18, 119:5, 119:9, 119:14, 119:17 depose[2] - 96:23, 97:23 DEPOSITION[1] - 1:9 deposition[18] - 2:5, 13:8, 27:21, 27:22, 28:19, 29:21, 33:11, 33:15, 35:7, 41:24, 49:15, 51:11, 97:24, 100:9, 119:21, 121:6, 122:5, 122:20 depravity[1] - 41:2 derivative[1] - 110:11 described[2] - 6:20, 105:25 DESCRIPTION[1] 4:2 description[1] 109:21 Desouza[3] - 49:19, 49:20, 52:5 DESOUZA[14] - 2:9, 48:22, 49:1, 50:1, 51:9, 51:14, 51:22, 55:4, 55:20, 59:5, 77:4, 117:18, 119:3, 119:19 destroy[2] - 93:9, 93:19 details[2] - 8:20, 75:7 differences[1] - 95:15 different[7] - 51:9, 51:15, 65:20, 68:8, 77:20, 78:25, 103:21 difficult[4] - 16:19, 33:24, 56:9, 75:2 difficulty[1] - 56:20 Dimartini[1] - 79:3 dinner[1] - 18:1 direct[1] - 116:3 direction[1] - 67:25 directly[5] - 23:16, 33:4, 33:7, 113:11, 113:14 director[1] - 67:14 directors[1] - 105:21 disclose[1] - 63:8 disclosing[1] - 42:22 disclosure[2] - 62:17, 62:21 discover[1] - 112:23 discussed[4] - 80:3, 80:10, 85:17, 85:18 discussion[4] - 14:2, 53:20, 92:15, 92:17 Discussion[3] - 51:2, 63:23, 119:21 discussions[4] 13:25, 46:15, 83:1, 92:17 dismiss[8] - 30:15, 30:25, 61:4, 62:3, 62:4, 62:6, 62:11, 114:11 dismissed[5] - 30:11, 30:12, 30:13, 30:24, 101:22 dispute[2] - 60:7, 60:10 disputed[2] - 23:19, 117:2 disputes[1] - 60:6 disputing[1] - 78:13 distributed[1] - 94:12 District[1] - 5:15 DISTRICT[1] - 1:1 divined[1] - 46:5 DIVISION[1] - 1:2 docs[1] - 59:14 document[6] - 55:9, 58:3, 58:7, 58:12, 77:3, 78:4 documents[33] - 9:2, 49:16, 51:16, 51:17, 52:1, 52:3, 52:15, 52:22, 53:24, 54:8, 54:12, 54:16, 55:7, 55:8, 55:11, 56:2, 56:11, 56:12, 56:15, 56:24, 57:2, 61:15, 61:18, 73:4, 73:5, 78:2, 78:9, 78:11, 104:5, 104:9, 108:11, 108:12, 112:15 done[7] - 53:19, 100:23, 113:9, 118:6, 119:5, 119:6 down[17] - 17:4, 17:5, 17:16, 20:9, 20:14, 50:15, 50:25, 62:15, 67:3, 85:23, 90:17, 94:18, 100:12, 100:15, 100:18, 103:1, 109:9 draft[3] - 69:18, 69:19, 115:7 draw[2] - 42:13, 42:19 Drive[1] - 2:3 drive[33] - 17:4, 17:5, 17:9, 17:14, 17:15, 17:24, 44:7, 50:6, 51:4, 51:6, 51:9, 51:15, 51:20, 52:4, 52:6, 52:22, 54:8, 54:16, 54:18, 54:21, 54:22, 55:1, 55:14, 55:16, 56:1, 56:20, 59:3, 63:17, 63:22, 73:6, 73:7, 76:24, 77:2 drives[1] - 17:11 driving[2] - 17:16, 17:21 drove[5] - 16:12, 16:14, 16:24, 17:22, 44:6 duality[1] - 41:1 duly[2] - 5:7, 120:6 during[6] - 9:4, 43:14, 67:18, 71:7, 71:25, 91:15 E e-mail[18] - 76:15, 76:21, 78:20, 79:24, 84:20, 84:23, 87:2, 89:2, 89:4, 92:16, 95:24, 96:10, 96:13, 96:17, 106:15, 106:21, 115:19, 117:3 e-mails[1] - 68:7 early[2] - 80:3, 82:25 126 earned[2] - 115:18, 116:7 earth[1] - 14:7 easier[1] - 77:17 easily[1] - 28:25 East[1] - 1:13 eating[1] - 55:19 echoes[1] - 105:7 Ed[1] - 84:4 editors[1] - 94:11 Edward[2] - 5:14, 5:19 EDWARD[5] - 1:9, 3:2, 5:6, 120:5, 122:2 EDWARDS[1] - 1:4 effect[2] - 95:16, 111:13 effort[2] - 8:11, 93:7 either[3] - 18:19, 50:3, 89:25 elsewhere[2] - 85:8, 85:9 emanate[1] - 31:7 emanated[2] - 97:15, 98:16 employed[1] - 71:2 employee[3] - 115:2, 121:9, 121:10 employment[6] 67:9, 68:3, 70:24, 71:10, 72:1, 84:17 encrypted[1] - 55:16 end[4] - 27:2, 92:8, 92:10, 106:11 ended[1] - 117:15 ends[1] - 14:7 engage[3] - 79:7, 79:16, 85:11 engaged[1] - 104:7 engaging[1] - 83:6 English[1] - 92:14 enhance[2] - 86:21, 87:3 enthusiastic[1] 80:14 entirely[2] - 36:24, 37:21 entities[1] - 23:5 entitled[2] - 12:9, 28:23 entries[1] - 73:14 ERROR[1] - 122:8 error[1] - 110:3 errors[1] - 122:5 Esquire[2] - 2:6, 2:9 establishment[5] 88:15, 89:7, 89:8, 89:14, 90:1 estate[2] - 42:17, 44:23 01/26/2016 10:32:45 AM Page 127 to 127 of 135 36 of 44 sheets ethical[2] - 95:14, 105:7 events[1] - 71:25 evidence[1] - 107:18 evidenced[1] - 117:6 exact[8] - 8:20, 9:6, 70:7, 70:8, 70:16, 70:18, 80:22, 105:16 exactly[8] - 5:23, 6:9, 7:25, 11:23, 19:4, 19:24, 55:11, 98:7 exam[12] - 11:21, 16:21, 22:22, 22:25, 23:2, 23:5, 45:16, 74:6, 74:7, 76:4, 78:8, 107:19 EXAMINATION[2] 3:3, 5:9 examination[9] 1:15, 5:12, 10:15, 14:9, 29:13, 29:16, 48:17, 49:16, 112:20 examined[1] - 5:8 example[7] - 16:16, 17:5, 38:8, 38:9, 88:3, 89:10, 89:20 except[1] - 43:7 exchange[8] - 84:20, 84:23, 95:24, 96:10, 96:13, 109:21, 115:19, 117:3 exchanged[1] 106:21 exclusively[2] - 85:4, 87:23 excuse[1] - 30:10 executive[1] - 67:14 Exhibit[9] - 72:3, 72:5, 72:6, 74:17, 97:10, 107:23, 108:15, 108:17 exhibit[3] - 72:8, 73:21, 110:23 Exhibits[1] - 107:16 EXHIBITS[1] - 4:1 expand[1] - 12:22 expect[1] - 57:12 experience[1] - 88:14 Expires[2] - 120:15, 121:24 explaining[2] - 116:4, 116:14 explore[1] - 12:9 explosive[1] - 106:6 express[1] - 89:4 expressed[6] - 80:25, 81:25, 85:16, 88:10, 106:9 expressing[1] - 89:2 expressive[1] 105:12 extraordinarily[2] 41:11, 66:16 extraordinary[1] 41:4 F fact[9] - 82:1, 82:7, 94:4, 112:18, 115:3, 115:16, 115:22, 116:24, 117:4 facts[14] - 60:14, 60:15, 80:23, 80:24, 85:15, 86:12, 89:10, 89:16, 112:3, 114:18, 115:12, 118:1, 118:2, 118:8 factual[2] - 114:9, 114:10 factually[1] - 61:1 faculty[1] - 81:7 fair[2] - 88:14, 104:10 fallible[1] - 109:25 false[3] - 31:13, 31:15, 32:25 familiar[7] - 47:25, 73:2, 73:16, 75:20, 75:23, 94:19, 110:25 family[1] - 39:1 far[15] - 34:22, 41:9, 52:1, 61:1, 67:10, 75:19, 83:2, 87:12, 88:18, 89:25, 110:5, 112:12, 115:17, 117:5, 117:10 fashion[1] - 8:1 fast[1] - 86:2 federal[1] - 101:22 feelings[1] - 106:12 fees[5] - 114:5, 115:18, 116:6, 117:5, 117:25 few[6] - 12:3, 56:9, 66:24, 88:3, 111:24, 112:9 FF078246[2] - 120:14, 121:23 file[3] - 13:5, 77:19, 115:9 filed[17] - 5:13, 30:15, 30:17, 30:21, 38:13, 44:25, 45:6, 59:22, 61:4, 62:5, 62:11, 89:6, 89:7, 101:15, 101:16, 101:18, 116:25 files[1] - 57:12 filibuster[1] - 118:17 filibustered[1] 118:19 filibustering[1] 118:21 filing[5] - 36:8, 37:8, 42:15, 89:23, 115:10 filled[3] - 37:15, 45:1, 45:3 filling[1] - 42:11 final[1] - 69:19 financed[2] - 114:25, 115:1 finances[11] - 10:13, 11:2, 11:12, 12:6, 12:23, 12:25, 14:6, 14:21, 14:24, 112:10, 112:16 financial[3] - 10:11, 24:12, 80:8 financially[2] - 7:6, 121:11 fine[9] - 6:12, 7:16, 57:8, 59:16, 76:19, 92:24, 96:22, 99:20, 111:23 finish[7] - 57:7, 102:23, 112:13, 114:13, 114:16, 116:9, 119:3 finished[2] - 73:24, 103:11 fired[1] - 89:9 firm[23] - 79:8, 79:16, 80:4, 80:5, 80:8, 82:11, 83:6, 83:7, 85:2, 85:19, 86:9, 90:12, 91:5, 91:14, 114:24, 115:1, 115:3, 115:16, 116:5, 116:18, 116:19, 116:25, 117:4 Firm[11] - 80:14, 85:3, 85:4, 85:22, 86:7, 86:8, 86:19, 87:23, 104:7, 106:2, 114:19 firm's[1] - 85:20 firms[3] - 80:13, 83:8, 83:21 first[17] - 8:25, 12:18, 12:21, 16:24, 20:21, 38:18, 40:3, 69:18, 75:5, 76:23, 82:13, 86:20, 88:4, 92:21, 98:18, 101:2, 104:2 First[2] - 105:6, 105:22 fishing[1] - 23:3 fit[1] - 40:24 five[3] - 34:8, 83:20, 99:24 flawed[2] - 40:15, 40:21 flaws[1] - 40:23 flip[1] - 72:16 FLORIDA[3] - 1:1, 120:2, 121:2 Florida[16] - 1:14, 1:17, 1:18, 2:4, 2:7, 2:10, 5:15, 5:20, 20:10, 20:12, 67:4, 105:6, 114:21, 115:4, 120:14, 121:23 flow[2] - 8:1, 8:8 folder[3] - 77:18, 77:23, 78:1 follow[1] - 81:19 following[1] - 116:17 follows[2] - 5:8, 88:23 food[2] - 18:25, 19:24 FOR[2] - 4:1, 122:8 foreclosure[3] - 6:20, 7:2, 7:5 foregoing[2] - 36:13, 121:6 Forest[1] - 5:19 forgot[1] - 79:11 format[1] - 56:6 formatted[1] - 59:3 forms[3] - 81:5, 81:6, 81:8 Fort[1] - 2:10 forth[3] - 67:7, 68:8, 71:7 Foundation[15] 30:22, 44:19, 45:6, 60:6, 66:10, 66:21, 67:3, 94:15, 95:13, 96:25, 105:6, 105:22, 106:1, 114:20, 115:5 foundation[13] 24:17, 67:5, 67:6, 67:13, 80:8, 82:6, 83:23, 84:6, 86:21, 87:4, 89:6, 115:12 foundation's[2] 82:6, 84:7 four[2] - 83:19, 100:1 Fourth[3] - 80:23, 81:11, 86:13 FPR[3] - 1:16, 120:13, 121:22 frame[4] - 35:22, 43:14, 61:19, 84:19 FRANK[1] - 2:6 frank[1] - 113:8 Frank[11] - 13:19, 59:16, 66:2, 72:12, 76:10, 98:13, 99:12, 104:22, 108:14, 113:10, 113:25 frankly[1] - 16:25 frequently[1] - 17:19 127 Friday[1] - 79:6 friendly[1] - 81:24 fuck[8] - 105:10, 108:4, 109:4, 109:6, 109:7, 110:12, 111:4 full[2] - 109:12, 118:8 funded[4] - 111:25, 114:4, 115:4, 117:24 funding[1] - 67:5 FURTHER[1] - 121:8 future[1] - 77:17 G gain[2] - 10:15, 112:21 gaining[1] - 45:17 garage[1] - 115:23 generally[5] - 70:10, 73:9, 73:10, 109:15, 110:7 generate[1] - 114:23 generating[7] 111:25, 112:4, 113:17, 113:23, 115:16, 117:7, 117:24 generosity[1] - 41:5 given[10] - 9:6, 11:10, 29:8, 36:25, 56:4, 80:13, 80:17, 81:25, 83:21, 121:7 glad[1] - 28:24 goal[1] - 29:1 Gomez[3] - 57:18, 57:23, 58:1 gosh[1] - 94:2 government[5] - 82:4, 82:8, 84:5, 85:19, 99:2 great[3] - 71:13, 95:21, 96:14 greater[1] - 114:21 Greg[6] - 47:5, 82:1, 82:9, 84:4, 85:19, 105:7 Group[2] - 2:3, 101:3 guess[7] - 49:11, 52:17, 82:18, 90:9, 100:9, 103:14, 118:6 Gulfstream[4] - 74:9, 89:19, 101:7, 101:19 guy[2] - 99:10, 101:4 guys[2] - 51:19, 77:18 gyrations[1] - 9:1 H habit[1] - 95:1 half[1] - 63:19 37 of 44 sheets Page 128 to 128 of 135 01/26/2016 10:32:45 AM halfway[1] - 104:21 hall[4] - 38:18, 38:21, 40:3, 41:25 hand[5] - 49:24, 110:6, 111:15, 111:17, 120:7 hands[1] - 8:3 hang[5] - 11:16, 35:21, 76:3 happy[26] - 12:24, 14:10, 14:19, 29:3, 50:20, 55:16, 55:24, 56:2, 56:4, 56:6, 56:21, 56:25, 57:2, 57:5, 58:20, 58:21, 58:22, 59:1, 97:1, 97:5, 112:12, 112:14, 118:9, 118:12, 119:10 harass[1] - 89:22 hard[22] - 51:4, 52:7, 52:22, 53:19, 54:8, 54:16, 54:18, 54:21, 54:22, 55:1, 55:14, 55:16, 56:1, 56:20, 59:3, 63:17, 63:22, 73:6, 73:7, 76:24, 77:2, 106:12 head[10] - 16:25, 31:18, 33:9, 34:4, 36:21, 54:4, 55:9, 69:21, 99:3, 101:14 hear[2] - 110:7, 117:19 heard[1] - 117:18 hearing[1] - 82:23 heinous[2] - 41:3, 41:4 help[9] - 14:23, 30:14, 56:1, 56:5, 58:10, 59:1, 92:25, 93:1 helpful[3] - 42:21, 71:12, 71:14 herein[1] - 5:7 hereto[1] - 122:21 hidden[1] - 112:23 hide[1] - 112:24 highly[2] - 82:2, 84:5 HILLSBOROUGH[2] 120:2, 121:2 himself[8] - 105:11, 108:4, 109:4, 109:6, 109:7, 110:12, 111:4 hire[1] - 90:12 hired[2] - 67:15, 91:5 hold[3] - 14:1, 48:11, 78:23 holder[1] - 8:2 holding[1] - 59:23 home[4] - 20:20, 67:3, 108:23, 108:25 honest[3] - 11:11, 39:12, 70:5 hoop[1] - 49:24 hoped[1] - 106:9 Hopkins[3] - 47:21, 47:24, 48:3 horrible[2] - 41:10, 41:13 hotel[2] - 105:19, 115:23 hours[1] - 19:7 house[4] - 6:19, 6:24, 7:6, 7:9 housing[1] - 18:25 I idea[7] - 20:9, 20:11, 37:22, 38:10, 44:12, 103:16, 103:19 identical[2] - 80:24, 86:12 IDENTIFICATION[1] 4:1 identification[5] 72:6, 74:17, 97:11, 107:16, 107:23 imagine[3] - 61:24, 101:16, 101:17 immediately[4] 30:25, 36:5, 36:20, 115:22 important[2] - 80:4, 82:8 imposed[1] - 117:1 impression[1] - 63:9 impressions[2] 62:15, 62:20 impropriety[1] - 80:7 imprudent[1] - 80:15 imprudently[2] 101:23, 101:25 in-person[1] - 92:17 Inc[3] - 2:3, 44:19, 66:10 inclined[2] - 79:7, 79:14 include[1] - 122:20 including[3] - 93:10, 93:22, 96:21 incorrect[1] - 21:20 INDEX[1] - 3:1 indicated[3] - 36:23, 58:2, 122:6 individually[2] 94:25, 107:22 induced[1] - 21:10 inflection[1] - 92:10 information[7] - 9:5, 9:6, 11:20, 13:21, 24:17, 36:15, 73:8 inspect[2] - 53:5 instances[1] - 42:9 instead[2] - 11:18, 26:9 instruct[1] - 23:24 instructing[1] 113:12 INSTRUCTIONS[1] 122:3 intended[4] - 89:3, 95:17, 112:20, 112:22 interaction[1] - 23:15 Intercontinental[1] 105:18 interest[4] - 80:8, 80:25, 81:25, 85:16 interested[3] - 86:10, 86:16, 121:12 interesting[1] - 80:20 interject[1] - 45:10 interrupts[1] - 102:23 invite[3] - 18:1, 18:2, 89:25 invited[2] - 17:25, 67:3 involve[1] - 67:9 involved[3] - 67:2, 82:22, 88:13 iron[1] - 59:14 irreconcilable[1] 95:14 IRS[4] - 85:5, 87:1, 87:17, 87:24 issue[7] - 56:22, 56:25, 84:25, 85:2, 89:5, 92:19, 115:20 issues[5] - 8:1, 8:8, 82:3, 82:8, 99:2 it'll[2] - 50:1, 75:1 itself[1] - 122:5 J Jackson[1] - 79:5 January[3] - 66:22, 67:12, 121:18 Joanne[1] - 11:9 job[2] - 30:22, 67:10 Joe[2] - 59:10, 72:12 Joel[12] - 5:13, 5:19, 13:2, 51:11, 54:15, 76:8, 77:11, 78:18, 79:2, 87:1, 94:19, 116:21 JOEL[6] - 1:4, 1:9, 3:2, 5:6, 120:5, 122:2 John[2] - 84:3, 115:24 Johnson[1] - 1:13 Jonathan[3] - 106:2, 115:25, 116:20 judge[3] - 18:14, 48:24, 58:2 Judge[4] - 10:21, 13:6, 51:18, 63:7 July[3] - 94:21, 108:8 June[19] - 67:16, 76:8, 76:12, 76:13, 76:15, 76:18, 78:19, 78:23, 78:25, 84:8, 84:14, 84:21, 91:15, 94:20, 95:19, 104:20, 104:21, 104:25, 105:4 juvie[1] - 93:3 K Kaney[1] - 84:3 keep[8] - 8:24, 13:7, 28:17, 40:6, 66:25, 67:1, 86:2, 113:19 Kelly[1] - 79:5 Kennedy[1] - 105:19 kept[2] - 9:10, 115:17 kick[1] - 86:1 kind[4] - 44:9, 86:23, 90:17, 103:25 kindly[4] - 15:10, 30:20, 56:11, 61:9 kindness[1] - 41:5 kinds[2] - 38:25, 40:6 knowing[1] - 70:16 knowingly[1] - 101:5 knowledge[7] 36:15, 37:1, 54:7, 55:13, 64:14, 64:17, 74:22 known[1] - 84:5 L lack[3] - 36:25, 68:15, 97:14 lady[1] - 32:9 laid[2] - 114:10, 114:11 Lakeland[24] - 5:20, 10:1, 20:21, 21:4, 21:6, 21:8, 21:10, 21:13, 21:17, 21:22, 22:5, 22:8, 22:11, 22:16, 22:17, 25:8, 25:10, 25:11, 25:19, 26:22, 116:3 landmark[2] - 85:20, 86:3 128 language[2] - 74:3, 111:10 laptop[1] - 55:4 large[2] - 80:12, 82:7 Large[3] - 1:18, 120:14, 121:23 largest[1] - 82:11 last[14] - 9:9, 14:19, 20:8, 25:17, 28:5, 46:1, 48:25, 51:10, 56:19, 76:23, 79:17, 100:21, 102:20, 102:21 late[1] - 90:16 Lauderdale[1] - 2:10 law[24] - 79:8, 79:16, 80:4, 80:5, 80:13, 82:11, 83:6, 83:7, 83:8, 83:21, 85:2, 85:19, 89:1, 90:12, 91:14, 114:24, 115:1, 115:3, 115:16, 116:5, 116:18, 116:19, 116:25, 117:4 Law[11] - 80:14, 85:3, 85:4, 85:22, 86:7, 86:8, 86:18, 87:23, 104:7, 106:2, 114:19 lawsuit[14] - 11:8, 23:3, 27:16, 45:5, 45:12, 46:2, 63:3, 63:5, 63:6, 74:5, 112:19, 115:10, 115:11 lawsuits[11] - 89:6, 89:8, 102:6, 104:8, 114:23, 115:7, 115:9, 115:11, 116:24, 117:1 lawyer[4] - 86:23, 87:11, 88:22, 88:23 lawyer's[1] - 26:10 lawyers[2] - 47:22, 88:20 least[7] - 8:6, 44:20, 80:6, 80:12, 83:7, 85:9, 115:6 leave[5] - 13:8, 20:20, 28:21, 72:13, 106:5 leaving[2] - 31:1, 88:12 lectured[1] - 28:20 left[1] - 30:22 legal[11] - 42:13, 42:20, 46:6, 46:9, 46:11, 46:12, 63:10, 83:23, 112:1, 114:5, 117:25 less[3] - 6:16, 6:17, 6:25 01/26/2016 10:32:45 AM Page 129 to 129 of 135 38 of 44 sheets letter[3] - 78:14, 78:18, 79:23 letting[1] - 118:7 level[1] - 11:3 liability[1] - 88:22 licensed[1] - 115:4 life[3] - 39:9, 95:22, 109:1 likely[1] - 79:5 limited[2] - 22:12, 41:24 Lincoln[1] - 105:19 line[6] - 22:22, 25:24, 43:8, 64:16, 102:12, 112:7 lines[1] - 122:6 linked[1] - 99:1 list[2] - 23:20, 37:25 listed[5] - 23:21, 38:5, 45:12, 74:11 literally[1] - 67:13 litigated[1] - 80:21 litigation[7] - 35:7, 41:24, 44:20, 45:15, 86:9, 104:5, 104:10 litigators[1] - 84:6 lived[3] - 5:21, 6:6, 6:24 LLP[1] - 1:13 loan[1] - 9:8 LOCATION[1] - 1:13 LoCicero[14] - 80:24, 81:24, 82:2, 82:5, 84:9, 84:11, 85:11, 90:10, 90:18, 90:19, 90:21, 90:22, 92:20 long-time[1] - 115:2 look[21] - 13:19, 34:5, 38:10, 46:21, 46:22, 49:22, 53:11, 55:6, 58:16, 63:14, 67:8, 72:10, 72:12, 87:14, 98:18, 98:21, 100:6, 109:18, 109:19, 113:8, 119:15 looked[1] - 73:13 looking[6] - 18:23, 33:24, 47:17, 53:12, 59:21, 73:24 looks[8] - 73:1, 73:16, 75:20, 75:23, 76:8, 88:18, 110:25 love[1] - 105:11 lower[1] - 55:18 lunch[1] - 81:18 lying[2] - 82:14, 99:7 M Mac[3] - 53:13, 56:23, 59:3 machine[1] - 55:23 Madison[1] - 1:13 mail[18] - 76:15, 76:21, 78:20, 79:24, 84:20, 84:23, 87:2, 89:2, 89:4, 92:16, 95:24, 96:10, 96:13, 96:17, 106:15, 106:21, 115:19, 117:3 mailed[1] - 49:8 mails[1] - 68:7 main[1] - 17:8 man[4] - 39:12, 41:1, 41:2, 70:5 managerial[1] - 115:2 manner[1] - 37:22 Manson[1] - 41:8 March[1] - 61:15 mark[9] - 22:3, 72:2, 74:16, 82:20, 92:8, 97:7, 97:13, 107:20, 122:5 MARKED[1] - 4:1 marked[7] - 72:6, 74:17, 97:10, 107:13, 107:16, 107:22, 107:23 Martin[4] - 5:11, 111:25, 114:4, 117:24 MARTIN[1] - 2:2 marty[1] - 119:17 Marty[21] - 12:16, 13:20, 14:4, 14:18, 31:6, 59:6, 85:1, 96:18, 97:17, 106:2, 108:3, 109:4, 109:6, 109:7, 109:11, 110:10, 110:11, 111:4, 118:18, 119:3 massive[1] - 14:6 matter[2] - 89:10, 89:20 mattered[1] - 115:9 mean[23] - 12:21, 16:23, 24:5, 50:5, 51:14, 58:5, 60:18, 60:22, 66:4, 66:6, 66:7, 75:20, 78:2, 80:24, 89:5, 89:9, 94:7, 97:20, 98:7, 100:10, 102:6, 107:7, 108:21 meanie[1] - 104:23 means[3] - 25:5, 25:7, 45:17 meanwhile[1] - 27:22 media[1] - 94:8 meet[31] - 9:25, 12:13, 12:14, 15:25, 16:4, 16:6, 16:13, 16:15, 16:17, 16:24, 17:2, 17:16, 17:19, 17:20, 17:22, 17:24, 17:25, 20:21, 20:22, 22:20, 24:6, 25:1, 25:6, 25:18, 25:21, 25:23, 26:5, 26:10, 26:12, 29:14, 30:23 meeting[10] - 21:17, 27:5, 38:15, 71:17, 104:4, 105:21, 107:7, 107:8, 107:10, 115:22 meetings[1] - 114:22 meets[3] - 104:24, 105:4, 105:5 member[2] - 82:11, 101:8 members[2] - 83:11, 83:18 memorandum[4] 67:21, 67:23, 68:6, 69:7 memory[5] - 35:9, 47:17, 71:13, 71:18, 71:24 men[2] - 41:3, 41:4 MENDOZA[4] - 1:16, 120:13, 121:4, 121:22 mental[3] - 62:15, 62:20, 63:9 mention[1] - 92:7 mentioned[4] - 34:14, 35:1, 85:15, 99:22 MEO[1] - 105:10 merit[3] - 46:3, 46:5, 46:8 meritless[1] - 46:2 met[25] - 9:24, 12:2, 12:15, 16:11, 16:16, 21:6, 22:11, 22:16, 22:17, 24:10, 24:11, 24:13, 25:5, 25:8, 25:9, 25:15, 38:20, 67:4, 81:18, 83:18, 101:2, 104:3, 105:25, 107:5 MIDDLE[1] - 1:1 Middle[1] - 5:15 might[10] - 30:2, 34:6, 58:14, 64:7, 67:8, 73:10, 77:7, 110:2 mind[7] - 35:13, 35:16, 43:18, 43:20, 85:10, 88:21, 115:12 mine[4] - 50:2, 50:3, 53:12, 106:11 minute[3] - 15:4, 48:11, 63:20 minutes[2] - 59:6, 88:3 mistaken[1] - 48:2 model[1] - 51:13 moderately[1] - 95:12 moderately-tone[1] 95:12 modify[1] - 9:8 Moganen[1] - 84:4 Monday[1] - 106:23 money[19] - 8:19, 8:24, 9:10, 11:11, 33:3, 40:6, 42:1, 60:7, 60:8, 60:11, 60:12, 60:16, 60:17, 60:18, 60:23, 60:25, 61:2, 89:22, 117:8 month[1] - 83:20 months[5] - 9:7, 19:5, 66:24, 100:21, 100:23 morning[1] - 119:2 mortgage[5] - 7:9, 7:11, 8:2, 9:1, 9:3 most[10] - 41:3, 41:4, 46:23, 56:2, 56:24, 79:5, 82:8, 86:16, 96:6, 96:7 Mother[1] - 41:7 motion[7] - 13:5, 61:4, 62:3, 62:4, 62:5, 62:11, 114:10 motivations[1] 22:14 mouth[3] - 40:4, 82:23, 105:17 move[5] - 15:2, 21:1, 32:3, 59:12, 78:22 MR[403] - 5:10, 6:13, 6:14, 7:12, 7:15, 10:7, 10:10, 10:18, 11:16, 11:23, 11:25, 12:2, 12:4, 12:7, 12:10, 12:11, 12:12, 12:17, 12:19, 12:20, 13:1, 13:15, 13:16, 13:24, 14:3, 14:14, 14:16, 15:3, 15:7, 15:8, 15:15, 15:19, 15:23, 16:20, 17:3, 17:10, 17:12, 18:6, 18:10, 18:11, 18:12, 18:13, 18:15, 18:17, 18:21, 19:23, 20:2, 20:5, 20:17, 20:19, 21:2, 21:3, 21:5, 22:21, 22:23, 22:24, 23:6, 23:7, 23:10, 23:13, 23:15, 23:18, 23:23, 24:1, 24:7, 129 24:9, 24:15, 24:20, 24:22, 24:23, 24:25, 25:4, 25:12, 25:14, 25:24, 26:2, 26:16, 26:17, 26:18, 26:19, 26:20, 27:11, 27:20, 28:1, 28:3, 28:5, 28:10, 28:15, 29:20, 29:22, 32:5, 32:6, 32:8, 32:13, 32:16, 32:20, 32:24, 34:12, 34:13, 34:20, 35:21, 35:23, 35:24, 36:1, 36:2, 36:6, 36:10, 36:11, 37:7, 37:10, 37:11, 37:14, 37:16, 38:2, 38:4, 38:6, 38:13, 38:17, 39:16, 39:17, 39:19, 39:20, 39:21, 41:15, 41:20, 41:22, 42:8, 42:25, 43:5, 43:6, 43:9, 43:10, 43:11, 45:10, 45:19, 45:23, 46:4, 46:13, 46:14, 46:17, 47:10, 47:11, 47:13, 47:14, 48:6, 48:8, 48:9, 48:12, 48:15, 48:22, 48:23, 49:1, 49:2, 49:3, 49:5, 49:7, 49:9, 49:10, 49:13, 49:14, 49:18, 49:20, 49:22, 49:25, 50:1, 50:3, 50:9, 50:10, 50:11, 50:18, 50:22, 51:1, 51:3, 51:9, 51:14, 51:22, 51:23, 51:25, 52:8, 52:9, 52:11, 52:13, 52:14, 52:16, 52:17, 52:23, 53:8, 53:9, 53:15, 54:2, 54:10, 54:11, 54:15, 54:20, 55:2, 55:4, 55:5, 55:6, 55:7, 55:20, 56:10, 57:6, 57:8, 57:11, 57:14, 57:16, 57:18, 58:4, 58:6, 58:7, 58:8, 58:14, 58:16, 58:17, 58:24, 59:5, 59:7, 59:9, 59:13, 59:16, 59:19, 59:20, 60:1, 60:2, 60:3, 60:4, 60:19, 60:20, 60:21, 61:11, 61:12, 61:14, 61:17, 61:23, 62:1, 62:4, 62:5, 62:7, 62:8, 62:12, 62:18, 62:19, 62:20, 62:22, 62:25, 63:12, 63:13, 63:19, 63:21, 63:24, 63:25, 39 of 44 sheets Page 130 to 130 of 135 01/26/2016 10:32:45 AM 64:8, 64:10, 64:11, 65:10, 65:11, 65:12, 65:14, 65:17, 65:19, 65:21, 65:22, 66:1, 66:5, 66:19, 66:25, 67:17, 69:11, 69:17, 70:9, 70:10, 70:13, 70:22, 70:23, 71:4, 72:2, 72:5, 72:7, 72:9, 72:11, 73:23, 74:4, 74:7, 74:10, 74:13, 74:15, 74:16, 74:20, 76:3, 76:5, 76:7, 76:9, 76:10, 77:1, 77:4, 77:5, 77:8, 79:20, 84:1, 84:16, 85:23, 85:25, 86:22, 87:7, 87:9, 87:10, 90:3, 90:4, 90:8, 91:10, 91:12, 91:13, 91:15, 91:16, 91:17, 91:20, 91:21, 91:22, 91:23, 91:24, 91:25, 92:13, 92:23, 93:11, 93:13, 93:14, 94:17, 94:19, 94:23, 95:1, 95:3, 95:7, 97:3, 97:7, 97:12, 98:12, 98:13, 98:14, 98:15, 98:18, 98:21, 98:23, 99:8, 99:10, 99:13, 99:19, 100:5, 100:8, 100:10, 100:14, 100:16, 100:17, 101:9, 101:10, 102:12, 102:15, 102:16, 102:19, 102:21, 103:1, 103:5, 103:6, 103:9, 103:11, 103:12, 104:18, 104:20, 104:21, 104:22, 105:13, 107:2, 107:13, 107:17, 107:24, 108:1, 108:12, 108:14, 108:16, 108:24, 109:2, 109:14, 113:2, 113:5, 113:7, 113:10, 113:13, 113:15, 113:24, 113:25, 114:3, 117:18, 117:20, 118:4, 118:15, 118:16, 118:24, 119:1, 119:3, 119:4, 119:7, 119:11, 119:16, 119:19 Mullins[1] - 84:4 multiple[2] - 21:18, 49:16 must[1] - 105:9 N name[7] - 5:11, 5:17, 46:20, 46:25, 99:21, 99:22, 109:12 name's[1] - 47:25 named[2] - 48:3, 82:23 names[2] - 46:18, 47:4 narrow[5] - 65:10, 65:15, 66:1, 92:13, 94:18 NE[1] - 2:10 necessarily[3] - 78:3, 80:11, 106:6 necessary[2] - 28:24, 55:25 need[18] - 21:24, 24:16, 33:22, 34:15, 34:16, 35:8, 47:17, 51:20, 52:25, 57:24, 72:17, 80:11, 81:7, 82:13, 86:17, 87:15, 106:5, 112:6 never[4] - 8:17, 29:18, 93:6, 93:7 new[1] - 48:22 Newport[1] - 2:3 newspaper[9] - 94:3, 94:11, 94:16, 97:14, 98:16, 98:19, 98:24, 107:15, 107:21 newspapers[4] 93:25, 94:2, 94:5, 94:7 next[7] - 29:14, 75:14, 76:18, 88:20, 103:1, 103:2, 116:20 nice[1] - 99:11 Nick[7] - 95:24, 96:1, 96:3, 96:10, 96:14, 106:21, 115:19 nigger[2] - 96:4, 96:17 NO [1] - 4:2 Nobles[7] - 80:21, 81:10, 85:12, 85:15, 86:10, 86:11 none[10] - 35:13, 35:16, 36:4, 36:19, 37:23, 43:18, 43:20 nonpriority[1] - 59:24 nonsensical[7] 11:9, 33:2, 45:5, 45:7, 46:2, 88:17, 89:11 Notary[3] - 1:17, 120:13, 121:22 note[2] - 63:8, 122:5 noted[1] - 122:21 notes[16] - 33:22, 33:24, 34:5, 34:16, 34:23, 35:9, 38:10, 46:21, 46:23, 47:18, 61:3, 61:7, 61:23, 62:3, 63:16, 73:5 nothing[7] - 5:3, 17:11, 37:2, 45:8, 73:15, 115:15, 117:7 Notice[1] - 1:15 notice[3] - 48:16, 49:4, 49:15 Number[2] - 120:14, 121:23 number[18] - 5:15, 9:23, 46:16, 56:12, 60:1, 74:23, 80:1, 80:5, 80:12, 82:7, 86:14, 88:14, 92:14, 94:10, 104:18, 106:3, 106:25, 117:23 numbered[1] - 75:1 O O'[3] - 2:5, 5:11, 50:14 O'BOYLE[227] - 2:2, 5:10, 6:14, 7:15, 10:10, 10:18, 11:23, 12:2, 12:7, 12:11, 12:12, 12:19, 13:1, 13:15, 14:16, 15:7, 15:8, 15:15, 15:19, 15:23, 17:3, 17:12, 18:10, 18:12, 18:15, 18:21, 19:23, 20:2, 20:5, 20:17, 20:19, 21:2, 21:5, 22:23, 23:6, 23:10, 23:15, 23:23, 24:7, 24:15, 24:22, 24:23, 25:4, 25:14, 26:2, 26:17, 26:19, 26:20, 27:20, 28:3, 28:10, 29:22, 32:6, 32:8, 32:13, 32:16, 32:20, 32:24, 34:13, 34:20, 35:23, 36:1, 36:6, 36:11, 37:10, 37:14, 37:16, 38:6, 38:17, 39:17, 39:20, 39:21, 41:22, 42:25, 43:6, 43:10, 43:11, 46:4, 46:13, 46:17, 47:11, 47:14, 48:8, 48:9, 48:15, 48:23, 49:2, 49:5, 49:9, 49:10, 49:14, 49:20, 49:25, 50:3, 50:10, 50:18, 51:1, 51:23, 51:25, 52:9, 52:13, 52:16, 52:23, 53:9, 53:15, 54:11, 54:15, 54:20, 55:2, 55:5, 55:7, 56:10, 57:6, 57:11, 57:16, 58:4, 58:7, 58:16, 59:7, 59:9, 59:16, 59:19, 59:20, 60:2, 60:4, 60:20, 60:21, 61:11, 61:14, 61:23, 62:4, 62:7, 62:12, 62:18, 62:20, 62:25, 63:12, 63:19, 63:24, 63:25, 64:10, 64:11, 65:11, 65:12, 65:17, 65:21, 66:1, 66:5, 67:17, 69:17, 70:10, 70:13, 70:23, 71:4, 72:2, 72:5, 72:9, 72:11, 73:23, 74:7, 74:13, 74:16, 74:20, 76:5, 76:7, 76:10, 77:1, 77:5, 77:8, 79:20, 84:1, 86:22, 87:9, 87:10, 90:4, 90:8, 91:12, 91:15, 91:17, 91:21, 91:23, 91:25, 92:23, 93:13, 93:14, 94:19, 95:1, 95:7, 97:7, 97:12, 98:13, 98:15, 98:23, 99:10, 99:19, 100:8, 100:14, 100:17, 101:10, 102:15, 102:19, 102:21, 103:5, 103:11, 103:12, 104:20, 104:22, 105:13, 107:2, 107:13, 107:24, 108:1, 108:14, 108:16, 109:14, 113:5, 113:10, 113:15, 113:25, 114:3, 117:20, 118:4, 118:16, 118:24, 119:4, 119:11, 119:16 O'Boyle[27] - 3:4, 14:4, 31:6, 50:17, 80:13, 85:3, 85:4, 85:22, 86:6, 86:8, 86:18, 87:23, 104:7, 106:2, 106:3, 108:3, 109:6, 109:11, 109:12, 110:10, 111:4, 111:25, 114:4, 114:19, 115:25, 117:24 130 O'Connor[1] - 11:10 OATH[1] - 120:1 oath[17] - 5:7, 6:1, 21:25, 23:20, 29:12, 33:13, 35:10, 45:4, 64:2, 97:18, 97:21, 97:22, 99:16, 109:20, 111:11, 111:19, 118:23 Oath[1] - 3:7 Obama[2] - 16:16, 16:18 object[5] - 10:7, 87:8, 100:10, 107:17, 112:7 objected[4] - 28:1, 57:15, 57:16, 103:9 objecting[5] - 41:17, 98:3, 113:2, 113:3, 113:4 objection[23] - 16:20, 17:10, 18:6, 22:21, 24:9, 25:12, 25:24, 27:11, 29:21, 41:15, 41:16, 43:5, 57:21, 57:25, 58:9, 61:21, 63:15, 76:3, 93:11, 101:9, 102:12, 116:5 objection's[1] - 24:20 objections[2] - 59:15, 116:23 obligation[2] - 46:10, 54:23 obliged[2] - 63:7, 63:8 obtuse[1] - 93:1 obviously[2] - 75:12, 85:6 occurred[1] - 58:5 October[3] - 1:11, 108:9, 120:8 OF[9] - 1:1, 1:9, 3:2, 120:1, 120:2, 120:2, 121:1, 121:2, 121:2 off-campus[1] - 81:9 offer[1] - 102:1 offered[3] - 53:5, 102:2, 107:18 office[12] - 26:10, 26:12, 26:23, 27:3, 27:4, 29:15, 82:24, 88:2, 93:10, 93:20, 96:3, 101:2 offices[1] - 104:3 official[1] - 120:7 old[1] - 82:12 once[3] - 9:24, 15:10, 59:14 one[66] - 11:19, 15:17, 19:23, 24:14, 31:8, 32:17, 32:20, 01/26/2016 10:32:45 AM Page 131 to 131 of 135 40 of 44 sheets 34:8, 34:12, 34:13, 34:14, 34:25, 35:1, 35:2, 35:3, 35:4, 35:5, 35:6, 38:9, 38:18, 40:3, 42:9, 42:19, 44:15, 45:23, 47:21, 48:22, 48:25, 49:1, 49:2, 51:10, 51:20, 52:24, 55:17, 56:8, 56:19, 63:12, 72:8, 72:9, 75:9, 75:11, 76:16, 76:18, 77:3, 78:19, 80:2, 80:4, 81:23, 82:9, 83:7, 85:12, 85:15, 87:18, 87:21, 96:4, 97:8, 103:1, 105:11, 107:4, 114:1, 115:14, 116:18, 118:18, 118:22 ones[5] - 34:7, 38:9, 57:16, 99:4, 107:21 online[1] - 33:18 open[17] - 10:13, 50:1, 50:2, 50:3, 50:11, 53:6, 53:8, 55:4, 59:3, 82:4, 82:8, 84:5, 85:18, 99:2, 112:24, 114:22, 117:15 open-ended[1] 117:15 opening[1] - 88:15 operate[1] - 81:2 operated[1] - 85:14 opined[1] - 88:24 opinion[5] - 88:22, 101:23, 101:25, 102:1, 102:2 opposed[1] - 116:14 OR[1] - 122:8 oral[1] - 1:15 order[4] - 10:15, 58:1, 71:15, 71:18 organization[1] 114:20 organizations[1] 116:16 original[1] - 110:24 Osiero[1] - 76:1 otherwise[3] - 63:7, 68:14, 110:3 ought[1] - 98:21 outside[4] - 15:5, 45:15, 82:13, 112:22 owe[8] - 60:7, 60:11, 60:12, 60:16, 60:18, 60:24, 61:2 owes[1] - 60:6 own[7] - 59:4, 62:23, 63:1, 63:6, 74:2, 104:5, 104:9 owns[1] - 44:13 P p.m[11] - 1:12, 15:6, 48:13, 59:8, 74:18, 76:15 page[17] - 36:8, 43:8, 43:9, 60:1, 60:2, 64:17, 64:19, 75:4, 75:10, 75:13, 75:14, 75:16, 75:17, 104:18, 117:22, 122:5, 122:6 PAGE[2] - 3:3, 4:2 Page[1] - 3:9 PAGE/ERRATA[1] 122:1 PAGE/LINE[1] - 122:8 pages[4] - 52:22, 74:23, 74:25, 122:7 paid[1] - 117:9 Palm[1] - 43:13 paper[1] - 38:1 paperwork[3] - 42:11, 42:15, 54:5 paragraph[3] - 92:9, 113:16, 113:22 pardon[5] - 26:17, 48:23, 52:13, 91:21, 103:18 parenthetically[1] 92:7 Park[1] - 5:19 parking[1] - 115:23 part[6] - 31:8, 62:1, 62:2, 62:9, 92:16, 95:23 partial[1] - 75:13 participate[1] - 29:3 participated[1] 33:12 particular[6] - 35:1, 56:9, 61:4, 79:22, 79:24, 80:19 particulars[2] - 35:10, 67:9 parties[1] - 121:9 parties'[1] - 121:10 partner[2] - 82:1, 85:20 partners[1] - 82:9 password[1] - 55:17 pay[2] - 8:11, 89:18 payment[6] - 7:19, 8:10, 8:21, 9:12, 30:23, 116:6 payments[8] - 7:13, 7:17, 7:22, 8:8, 8:11, 8:22, 9:4, 9:9 PC[4] - 53:14, 55:23, 56:23, 59:4 PDFs[1] - 56:25 peaches[2] - 55:18, 55:19 penalty[2] - 36:12, 64:13 pending[5] - 15:10, 23:4, 24:24, 45:15, 59:23 penny[1] - 89:17 people[12] - 17:16, 17:19, 40:15, 40:20, 40:23, 82:3, 89:22, 89:23, 93:10, 94:7, 102:3, 117:8 per[2] - 115:7, 117:1 perfectly[1] - 75:12 periodically[1] - 9:4 perjure[2] - 36:16, 36:17 perjury[2] - 36:12, 64:13 person[5] - 39:13, 68:15, 92:17, 116:18, 116:19 personally[3] - 44:24, 71:13, 120:5 pertain[12] - 12:25, 23:2, 23:11, 23:13, 24:9, 27:12, 27:13, 41:16, 45:11, 65:24, 74:4 pertains[12] - 11:18, 12:23, 13:18, 14:23, 16:21, 18:18, 22:24, 23:9, 24:11, 38:4, 61:19, 107:18 Peterson[13] 104:16, 104:25, 105:4, 105:5, 105:15, 108:3, 109:3, 109:22, 110:10, 110:19, 111:3, 111:12, 115:23 Peterson's[3] - 108:9, 108:19, 109:20 petition[1] - 37:12 philosophical[1] 95:15 phone[10] - 9:23, 10:22, 85:1, 95:20, 115:24, 116:1, 116:17 phrase[1] - 39:19 piece[1] - 38:1 piles[1] - 57:12 pinpoint[1] - 56:8 place[1] - 48:1 placed[1] - 54:8 places[1] - 25:15 plane[1] - 17:2 play[1] - 117:20 playing[1] - 58:20 pleadings[1] - 63:10 plethora[1] - 34:24 pockets[1] - 89:11 point[8] - 8:7, 42:6, 59:1, 79:6, 79:13, 89:24, 102:22, 104:4 pointed[1] - 29:13 politically[1] - 83:24 Pope[1] - 1:13 popped[1] - 16:25 poppycock[1] - 88:17 position[2] - 42:19, 116:14 possessed[2] 20:20, 21:8 possession[1] 61:24 possibility[2] - 67:6, 88:8 possible[6] - 30:23, 36:24, 37:21, 78:1, 110:1, 110:2 possibly[4] - 23:20, 42:22, 66:7, 82:15 post[1] - 37:12 post-petition[1] 37:12 potential[5] - 31:5, 37:17, 41:23, 44:18, 74:11 PowerPoint[2] 77:19, 77:21 practice[3] - 112:1, 114:5, 117:25 preceding[16] 15:13, 15:21, 19:25, 20:3, 24:3, 28:7, 32:11, 32:18, 32:22, 45:21, 45:24, 69:15, 102:24, 103:3, 103:7, 106:19 precipitated[1] 106:24 precise[1] - 35:11 preemptive[1] - 85:18 preferred[1] - 68:3 preparation[3] 62:15, 63:10, 71:8 prepare[6] - 70:21, 71:16, 73:1, 73:22, 74:2, 74:21 prepared[17] - 35:17, 67:24, 67:25, 68:1, 68:11, 69:19, 71:8, 71:23, 72:20, 72:21, 73:7, 73:12, 75:21, 95:12, 106:8 131 preparing[1] - 71:1 presence[2] - 96:2 present[1] - 36:20 presented[3] - 35:19, 42:14, 110:23 preserve[1] - 105:8 President[2] - 16:16, 16:17 press[6] - 90:2, 90:10, 91:2, 94:12, 95:12, 106:8 presumably[3] 22:15, 79:6, 95:22 presume[1] - 73:21 pretty[1] - 95:12 prevented[1] - 101:7 previous[1] - 30:7 previously[2] - 56:3, 57:2 prices[1] - 18:25 principally[1] - 89:1 PRINCIPE[165] - 2:6, 6:13, 7:12, 10:7, 11:16, 11:25, 12:4, 12:10, 12:17, 12:20, 13:16, 13:24, 14:3, 14:14, 15:3, 16:20, 17:10, 18:6, 18:11, 18:13, 18:17, 21:3, 22:21, 22:24, 23:7, 23:13, 23:18, 24:1, 24:9, 24:20, 24:25, 25:12, 25:24, 26:16, 26:18, 27:11, 28:1, 28:5, 28:15, 29:20, 32:5, 34:12, 35:21, 35:24, 36:2, 36:10, 37:7, 37:11, 38:2, 38:4, 38:13, 39:16, 39:19, 41:15, 41:20, 42:8, 43:5, 43:9, 45:10, 45:19, 45:23, 46:14, 47:10, 47:13, 48:6, 48:12, 49:3, 49:7, 49:13, 49:18, 49:22, 50:9, 50:11, 50:22, 51:3, 52:8, 52:11, 52:14, 52:17, 53:8, 54:2, 54:10, 55:6, 57:8, 57:14, 57:18, 58:6, 58:8, 58:14, 58:17, 58:24, 59:13, 60:1, 60:3, 60:19, 61:12, 61:17, 62:1, 62:5, 62:8, 62:19, 62:22, 63:13, 63:21, 64:8, 65:10, 65:14, 65:19, 65:22, 66:19, 66:25, 69:11, 70:9, 70:22, 72:7, 74:4, 74:10, 74:15, 76:3, 76:9, 84:16, 41 of 44 sheets Page 132 to 132 of 135 01/26/2016 10:32:45 AM 85:23, 85:25, 87:7, 90:3, 91:10, 91:13, 91:16, 91:20, 91:22, 91:24, 92:13, 93:11, 94:17, 94:23, 95:3, 97:3, 98:12, 98:14, 98:18, 98:21, 99:8, 99:13, 100:5, 100:10, 100:16, 101:9, 102:12, 102:16, 103:1, 103:6, 103:9, 104:18, 104:21, 107:17, 108:12, 108:24, 109:2, 113:2, 113:7, 113:13, 113:24, 118:15, 119:1, 119:7 Principe[3] - 50:6, 73:23, 102:22 pro[1] - 104:5 Pro[1] - 2:2 problem[6] - 39:11, 50:4, 50:13, 53:17, 57:9, 59:15 problematic[1] - 80:1 proceeding[2] 10:16, 112:22 produce[14] - 50:12, 50:13, 52:2, 52:11, 52:18, 54:5, 54:23, 54:24, 55:12, 56:17, 114:4, 115:6, 117:1, 117:25 produced[8] - 51:10, 52:2, 52:4, 53:19, 56:19, 57:1, 57:4, 112:1 producing[1] - 57:21 production[1] - 76:24 Professional[1] 1:17 profit[5] - 111:25, 112:4, 113:17, 113:23, 117:24 profit-generating[5] 111:25, 112:4, 113:17, 113:23, 117:24 program[3] - 77:20, 91:19, 116:21 prohibited[1] - 10:14 proper[1] - 29:21 proposed[1] - 83:10 proposing[1] - 83:19 proprietary[2] 81:13, 81:14 prosecute[1] - 89:23 prosecution[1] 89:20 prostitution[1] 40:11 protective[1] - 57:25 provide[5] - 9:5, 54:7, 55:16, 56:2, 112:15 provided[19] - 49:18, 53:2, 53:24, 54:2, 54:6, 54:9, 54:12, 56:3, 56:13, 58:11, 63:17, 73:6, 73:20, 76:22, 76:25, 78:12, 95:10, 104:2, 104:4 proxy[1] - 115:5 prudent[1] - 83:25 Public[4] - 1:17, 115:13, 120:13, 121:22 public[11] - 81:16, 81:20, 82:3, 85:21, 86:4, 102:6, 104:1, 104:8, 105:9, 106:6, 114:22 pull[3] - 58:17, 77:2, 78:16 pulled[1] - 100:8 purchase[1] - 75:8 purport[1] - 42:12 purporting[1] - 73:21 purpose[2] - 18:2, 94:13 PURSUANT[1] - 1:15 put[16] - 35:22, 55:14, 57:25, 58:24, 71:14, 97:21, 110:6, 111:15, 111:17, 111:18, 111:24, 113:16, 113:22, 117:23, 118:9, 118:11 putting[2] - 58:21, 92:8 Q questionable[1] 88:19 questioning[4] 22:22, 25:25, 102:13, 112:7 questions[45] - 10:12, 10:13, 10:25, 11:5, 11:8, 11:19, 12:24, 14:11, 14:12, 14:20, 18:3, 18:8, 18:20, 18:22, 18:24, 19:3, 19:4, 23:1, 23:8, 23:11, 27:18, 28:17, 28:22, 29:12, 29:15, 46:11, 46:23, 58:14, 59:10, 66:1, 66:2, 74:4, 74:15, 86:17, 97:25, 98:4, 98:10, 111:24, 112:9, 112:13, 112:14, 116:9, 118:6, 118:20, 119:11 quick[5] - 50:23, 57:10, 63:22, 72:10, 72:17 quit[1] - 98:9 quite[3] - 68:1, 80:20, 93:13 quota[1] - 117:1 quote[1] - 105:10 R raised[1] - 84:25 rarely[1] - 17:14 rather[1] - 52:3 rationale[2] - 85:3, 87:22 re[1] - 1:3 reach[1] - 93:8 reached[1] - 93:8 read[33] - 15:13, 15:19, 15:21, 19:18, 19:25, 20:3, 24:3, 28:7, 32:8, 32:11, 32:16, 32:18, 32:22, 36:7, 36:13, 45:21, 45:24, 69:11, 69:15, 72:17, 73:25, 78:14, 86:25, 87:20, 102:19, 102:24, 103:3, 103:7, 106:19, 108:21, 122:4, 122:20 real[6] - 50:22, 57:9, 63:22, 72:10, 72:16, 115:13 really[3] - 58:19, 106:15, 112:6 reason[6] - 8:15, 8:17, 24:18, 55:14, 55:21, 106:7 reasonable[2] 55:25, 56:6 reasons[3] - 22:10, 80:2, 80:5 recant[5] - 14:5, 38:24, 39:7, 40:4, 40:7 receive[1] - 48:16 recently[2] - 100:19, 100:20 Recess[4] - 15:6, 48:13, 59:8, 74:18 recognize[4] - 46:22, 73:14, 73:15, 74:2 recollection[4] 70:20, 88:7, 93:7, 111:11 record[31] - 5:18, 14:15, 15:4, 24:21, 33:13, 36:22, 48:12, 50:22, 50:24, 51:1, 51:2, 51:3, 51:23, 57:9, 57:10, 57:11, 59:5, 59:17, 63:22, 63:23, 63:24, 78:15, 81:20, 88:4, 96:24, 102:5, 118:10, 118:11, 119:20, 119:21, 121:7 Records[1] - 115:13 records[14] - 56:7, 56:9, 57:4, 72:24, 77:6, 78:3, 81:17, 82:3, 85:21, 86:4, 102:6, 104:1, 104:8, 114:22 refer[3] - 85:8, 86:17, 104:19 reference[2] - 27:5, 77:17 referred[7] - 61:6, 85:7, 96:17, 110:3, 110:17, 110:19, 115:11 referring[2] - 41:18, 63:17 reformat[2] - 56:1, 58:23 refresh[5] - 35:9, 47:17, 71:13, 71:18, 74:19 refreshing[1] - 71:24 refuse[1] - 18:15 refused[4] - 8:9, 8:13, 81:12, 96:12 refusing[3] - 10:23, 14:17, 14:22 regarded[2] - 82:2, 84:5 regarding[2] - 14:21, 71:21 regularly[2] - 85:21, 86:6 reimbursed[1] - 51:21 relate[4] - 11:20, 12:6, 14:9, 25:25 related[2] - 10:17, 11:1 relates[6] - 10:8, 12:5, 12:8, 27:16, 71:2, 71:5 relating[4] - 71:9, 99:2, 112:15, 112:16 relationship[4] 90:13, 96:24, 101:6, 102:10 relative[2] - 121:8, 121:10 132 release[3] - 94:12, 95:12, 106:9 relevant[12] - 11:12, 18:7, 24:25, 74:6, 74:7, 74:8, 74:9, 74:10, 76:4, 93:11, 93:13 rely[4] - 110:9, 110:12, 110:13, 110:14 remember[26] - 8:3, 19:24, 34:1, 34:4, 34:9, 34:11, 34:25, 46:24, 47:2, 47:3, 55:10, 58:1, 69:22, 75:10, 82:21, 88:5, 96:1, 99:14, 99:15, 99:16, 101:3, 104:14, 107:6, 107:7, 107:10 remind[1] - 37:7 remote[1] - 112:18 repeat[2] - 79:10, 105:1 repeatedly[6] - 95:21, 96:12, 97:21, 106:14, 115:21, 117:5 repetitive[1] - 75:13 rephrase[3] - 16:1, 16:9, 16:22 report[1] - 121:5 REPORTED[1] - 1:16 REPORTER[20] - 5:1, 5:5, 19:19, 32:10, 48:14, 51:24, 59:18, 69:14, 79:9, 79:13, 83:12, 83:14, 86:3, 102:20, 105:1, 106:17, 107:14, 107:20, 109:8, 121:1 Reporter[2] - 1:17, 3:8 reporter[18] - 15:14, 15:22, 20:1, 20:4, 24:4, 28:8, 32:12, 32:19, 32:23, 45:22, 45:25, 69:16, 97:13, 98:19, 102:25, 103:4, 103:8, 106:20 reporter's[5] - 26:12, 26:23, 27:3, 27:4, 29:15 reporters[1] - 94:11 reports[1] - 52:5 represent[3] - 82:5, 84:6, 104:7 represented[3] - 48:3, 90:5, 90:20 representing[5] 27:16, 58:1, 90:9, 01/26/2016 10:32:45 AM Page 133 to 133 of 135 42 of 44 sheets 91:1, 106:25 request[10] - 58:3, 58:7, 63:13, 75:25, 76:23, 78:5, 81:17, 81:21 requested[6] - 9:3, 51:17, 56:8, 61:12, 61:13, 81:9 required[1] - 122:6 requirement[1] 83:23 reread[2] - 61:14, 61:16 resend[2] - 95:24, 106:14 resign[2] - 95:10, 106:8 resignation[3] 106:7, 106:22, 106:23 resigned[2] - 67:16, 95:18 resources[1] - 89:19 respect[1] - 80:7 response[6] - 20:2, 23:3, 42:17, 56:12, 106:3, 112:13 responsibilities[1] 67:10 responsive[1] - 78:4 result[1] - 40:13 retract[3] - 95:23, 96:13, 106:14 returns[2] - 58:11, 58:18 revenue[1] - 115:16 revenue-generating [1] - 115:16 review[2] - 61:3, 117:7 review-generating[1] - 117:7 reviewed[1] - 46:6 RICO[7] - 89:9, 89:20, 101:15, 101:16, 101:17, 101:18, 101:21 rights[1] - 114:21 Rights[1] - 88:13 RING[1] - 83:16 Ring[11] - 75:24, 79:2, 79:4, 80:16, 83:10, 83:16, 90:4, 91:18, 95:20, 104:3, 115:25 road[2] - 17:8, 17:16 roads[2] - 17:19, 17:21 Robert[4] - 9:18, 9:20, 85:13, 85:15 room[2] - 38:23, 89:12 round[1] - 8:25 rudely[1] - 102:22 Rule[1] - 48:17 Ruppel[1] - 1:13 Russell[1] - 79:3 Ryan[10] - 100:24, 101:7, 102:4, 102:9, 103:16, 103:19, 103:23, 104:2, 104:3, 104:4 S sadly[2] - 112:3, 114:19 sake[1] - 83:25 Samuel[2] - 44:17, 44:18 sarcasm[1] - 25:13 satisfied[1] - 68:2 save[2] - 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18:24, 52:4, 58:14 typo[1] - 85:7 U ultimate[2] - 114:18, 115:14 ultimately[2] - 68:10, 114:23 unable[1] - 55:21 unanimous[1] - 46:7 unclear[1] - 111:10 under[25] - 5:7, 5:25, 21:25, 23:19, 29:12, 33:13, 35:10, 36:12, 45:3, 46:10, 64:2, 64:13, 77:23, 84:16, 97:4, 97:18, 97:21, 97:22, 99:16, 109:20, 111:11, 111:18, 111:19, 118:23 undersigned[1] 120:4 undiplomatic[1] 116:3 unfair[1] - 112:21 unfolded[1] - 71:25 unfortunately[1] 13:2 UNITED[1] - 1:1 United[4] - 30:5, 53:25, 54:13, 56:13 university[3] - 81:4, 81:7, 81:15 unknowingly[1] 101:5 unknown[2] - 36:23, 37:22 01/26/2016 10:32:45 AM Page 135 to 135 of 135 44 of 44 sheets unleash[1] - 14:6 unless[4] - 8:5, 50:4, 63:7, 95:4 unlimited[1] - 89:18 unpleasantness[2] 95:22, 96:15 unquote[1] - 105:11 unresolved[1] - 95:14 unsatisfactory[1] 34:23 unsavory[1] - 88:18 unsecured[2] - 59:24 up[13] - 26:22, 27:2, 28:21, 29:7, 29:14, 53:6, 53:8, 58:17, 77:2, 81:12, 85:3, 88:16, 89:9 upcoming[1] - 81:8 updated[2] - 9:5, 104:9 upward[1] - 92:10 USF[3] - 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97:23 well-known[1] - 84:5 West[3] - 2:3, 2:7, 82:12 Westshore[1] 105:19 wherein[1] - 99:21 white[2] - 55:18, 55:19 whitepeachestasteg ood[1] - 55:17 whole[4] - 5:2, 14:13, 102:2, 111:20 wife[2] - 30:13, 39:3 William[1] - 79:4 willing[3] - 16:8, 82:5, 84:6 willingness[1] - 36:25 wise[1] - 16:13 withdraw[3] - 96:9, 96:13, 96:16 Witmer[3] - 100:24, 101:7, 102:4 WITNESS[4] - 5:4, 120:7, 122:2, 122:3 Witness[1] - 101:14 witness[3] - 5:7, 121:7, 122:23 135 woman[1] - 48:2 word[4] - 55:17, 72:17, 75:5, 99:14 words[14] - 70:7, 70:8, 70:12, 70:14, 70:15, 70:16, 70:18, 77:22, 82:23, 99:17, 103:14, 105:16, 111:12 works[3] - 50:16, 70:25, 97:24 world[5] - 24:18, 53:20, 74:13, 91:9, 94:3 worried[3] - 87:1, 87:17, 87:19 wreck[1] - 39:9 writing[3] - 68:13, 88:11, 115:6 written[4] - 85:22, 86:6, 88:12, 95:10 wrote[2] - 62:15, 84:25 Y year[6] - 9:14, 44:11, 76:9, 76:23, 82:13, 88:4 years[13] - 5:24, 6:2, 6:5, 6:11, 6:15, 6:16, 6:17, 6:25, 9:16, 82:12, 86:14, 88:14 yes-or-no[1] - 35:15 YMCA[1] - 25:21 you-all[1] - 56:20 young[1] - 32:9 yourself[3] - 36:16, 89:7, 118:12 YouTube[4] - 33:16, 33:17, 33:18, 41:25 .pdf 100120~1.pdf 10.01.2015 - In re Chandler - Condensed.pdf application/pdf 06BB970C35A92D4F859A07D5DAFDB80B@gulf-stream.org EnUs 10.01.2015 - In re Chandler.pdf1001MRCHANDLER 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 1 UNITED STATED BANKRUPTCY COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION In re: JOEL EDWARDS CHANDLER and DEBORAH CHANDLER, Debtors. ] ] ] ] ] ] Case No.: 8:14-bk-142230-KRM Chapter 7 VIDEOTAPED DEPOSITION OF JOEL EDWARD CHANDLER DATE: October 1, 2015 TIME: 1:47 p.m. - 5 p.m. LOCATION: Johnson, Pope, Ruppel & Burns, LLP 403 East Madison Street Suite 400 Tampa, Florida 33602 PURSUANT TO: Notice, upon oral examination REPORTED BY: VANESSA MENDOZA, FPR Florida Professional Reporter Notary Public State of Florida at Large 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 2 APPEARANCES Appearing Pro se: MARTIN O'BOYLE Commerce Group, Inc. 1280 West Newport Center Drive Deerfield Beach, Florida 33442 (Mr. O' Boyle videotaped deposition.) Counsel for Debtors: FRANK PRINCIPE, Esquire 2805 West Busch Boulevard, Suite 100 Tampa , Florida 33618 Counsel for CAFI: DANIEL DESOUZA, Esquire 101 NE 3rd Avenue, Suite 1500 Fort Lauderdale, Florida 33301 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 3 INDEX TESTIMONY OF JOEL EDWARD CHANDLER EXAMINATION PAGE: By Mr. O'Boyle 5 Certificate of Oath 120 Certificate of Reporter 121 Signature Page 122 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 4 EXHIBITS MARKED FOR IDENTIFICATION: NO. DESCRIPTION PAGE 1 Composite documents 72 2 Composite documents 74 3 Composite documents 107 4 Composite documents 107 5 Composite documents 107 6 Composite documents 97 (Retained by Mr. O'Boyle) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 5 THE COURT REPORTER: Do you swear or affirm the testimony you give will be the truth, the whole truth, and nothing but the truth? THE WITNESS: I do. THE COURT REPORTER: Thank you. JOEL EDWARD CHANDLER, the witness herein, being duly sworn under oath, was examined and testified as follows: EXAMINATION BY MR. O'BOYLE: Q. Mr. Chandler, my name is Martin O' Boyle, and I am here to take a 2004 examination of you in connection with the bankruptcy that has been filed by you -- Joel Edward Chandler, Senior, and Deborah D. Chandler in the Middle District of Florida. And it is case number 8:14-bravo-kilo-14223-kilo-romeo-mike. Could you state your name and address for the record, please? A. Joel Edward Chandler; 1355 Forest Park Street, Lakeland, Florida 33803. Q. And, Mr. Chandler, how long have you lived there? A. I don't know exactly. Q. Okay. Is it more than 50 years? A. You're asking me to speculate, and I'm under 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 6 oath. Q. No, I'm asking you, is it more than 50 years? A. I said I don't know. I've already answered your question. Q. Okay. So it may be more than 50 years? A. You asked me if I knew how long I have lived there. Q. Uh-huh. A. I don't know exactly. Q. Right. I know that. And I asked you if it was more than 50 years and if maybe it is more than 50 years, that's fine. MR. PRINCIPE: You can answer. BY MR. O'BOYLE: Q. If it's not 50 years, just say "no." A. It's less than 50 years. Q. Very good. Is it less than 20 years? A. I don't know. Q. Okay. And I understand that house that you just described is in foreclosure; is that correct? A. No. Q. It's not, okay. What is the status of it? A. I don't understand the question. Q. Okay. There's a house that you've lived in less than 50 years, correct? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 7 A. Yes. Q. Okay. And you said it's not in foreclosure, correct? A. That's what I said, yes. Q. Yes. So is it -- if it's not in foreclosure is there a status to the house? Financially is there a status? A. I don't understand the question. Q. Okay. Do you have a mortgage on the house? A. Yes. Q. What's the status of the mortgage? MR. PRINCIPE: I think he's asking is it current? Are you current on the payments? A. Is that the question? BY MR. O'BOYLE: Q. Well, that's fine. Are you current on the payments? A. I'm sorry, can you state the question? Q. Yeah. I said are you current on the payment? A. No, I'm not. Q. Okay. And why not? A. Because I haven't made the payments. Q. Why not? A. In the beginning -- and I couldn't tell you exactly what the dates are we're talking about -- I was 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 8 -- I had cash flow issues on a temporary fashion. And when I contacted the mortgage holder who at the time -- I can't remember who it was now because it's changed hands so many times -- they basically told me that they couldn't talk to me about making any arrangements unless it was at least 90 days in arrears. So I accommodated them, at which point my cash flow issues were gone. And when I submitted payments they sent them back and they refused to accept any more payment. Q. So you did make an effort to pay the payments? A. Oh, yes. Q. Uh-huh. And they just refused to accept them? A. Yes. Q. And the reason again is? A. You'd have to ask them. Q. Okay. So they never gave you a reason? A. No. Q. Okay. They just sent you the money back? A. I don't recall the exact details, but they would not accept payment. Q. Okay. Did you ever send the payments? A. Oh, yeah, I did. Q. Okay. So did they keep the money? A. The first round they didn't. Then we did a - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 9 went through all the gyrations of a mortgage adjustment. I submitted to them all the documents that they requested, and I made I think it was 9 or 10 mortgage payments and periodically during that time they would ask to -- for updated information. I would provide to them the exact same information I'd given them before. And after, like I said, I think it was about 10 months or so they said that they were not going to modify the loan. That's the last time I made any payments to them, but they kept all that money. Q. So it's been how long since you've made a payment? A. I don't know. Q. More than a year? A. Yes. Q. More than two years? A. I don't know. Q. Okay. Do you know a Robert Sweetapple? A. I'm sorry? Q. Do you know a Robert Sweetapple? A. I do. Q. How? A. I have spoken to him on the phone a number of times and met him once. Q. And where did you meet him? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 10 A. In Lakeland. Q. I see. And how did you -- how did you get to speak to him? A. I'm sorry, what does this have to do with the bankruptcy? Q. We'll -MR. PRINCIPE: Well, I object right now because tell us how it relates to the bankruptcy, if you know. MR. O'BOYLE: I think it has to do or may have to do with his financial condition. A. If you want to ask me questions about my finances, I'm an open book. I'll answer any questions, but you know and I know that you are prohibited from attempting to use a 2004 examination in order to gain an advantage in an adversarial proceeding that is not related to the bankruptcy. BY MR. O'BOYLE: Q. Well, thank you for sharing that with me. Would you now answer my question? A. No, I won't. And if you'd like to get Judge May on the phone, please do. Q. Okay. So you're refusing to answer that question? A. I'm not going to answer any questions that are 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 11 not related to the bankruptcy. If you want to ask me anything you want to ask me about my finances, I will do my dead level best -Q. Okay. A. -- to answer your questions, but let me be clear. Let's just get it out on the table right now. If you're going to turn this into a circus where you want to ask a bunch of questions about CAFI lawsuit or your nonsensical claim or about Bob Sweetapple or about Joanne O'Connor, if you want to ask me if they've given me any money, I'll give you an honest answer; but beyond finances, it's not relevant to this and we're not going to talk about it. Q. Okay. A. So why don't we do this? MR. PRINCIPE: Hang on. Hang on. Hang on. Before we get going here, why don't you ask him how it pertains to the bankruptcy instead of asking 37 questions and then maybe asking one question that could relate to it so you can use the information? Make sure you stick to what a 2004 exam is. That's all we're asking. MR. O'BOYLE: I think that's exactly what I'm doing. MR. PRINCIPE: Well, you asked him of Bob. He 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 12 told you. MR. O'BOYLE: He told me he met him and spoke with him a few times. MR. PRINCIPE: Okay. Well, then ask another question that relates to the bankruptcy or his finances that relate to the bankruptcy. MR. O'BOYLE: Well, I think having to do with Sweetapple relates to the bankruptcy. That's what I think, and I'm entitled to explore it. MR. PRINCIPE: Ask the question. MR. O'BOYLE: Okay. BY MR. O'BOYLE: Q. How did you come to meet Mr. Sweetapple? When I say "meet" -- you said you spoke to him I assume -- did you speak to him before you met him? A. Ask me a question about the bankruptcy, Marty. MR. PRINCIPE: Ask the question. Just ask a question first. MR. O'BOYLE: I think I'm asking it. MR. PRINCIPE: You said "did you speak to him before?" I mean, just ask a question first and then don't expand on something else. He can ask that if it pertains to finances to your bankruptcy. A. And I'm happy to answer any questions that pertain to my finances. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 13 BY MR. O'BOYLE: Q. Unfortunately, Joel, you're not the sole arbiter here. A. Right. So why don't we do this? Why don't we stop and why don't you file a motion to compel and let's see what Judge May has to say? Q. Well, we're going to keep going. And if you want to leave the deposition, that will be something that you will have decided to do. A. Well, I'm not going to answer your question, so ask something else. Q. You're not going to ask -- you're not going to answer that question? A. No. MR. O'BOYLE: Counsel? MR. PRINCIPE: I think you can -- I think you can answer that question. He just wants to know how you know him as it pertains to the bankruptcy. THE DEPONENT: Look, Frank, it's as simple as this. What Marty is attempting to do is to get at the information that he threatened me over before. When we were here before and he told me that he wanted me to -MR. PRINCIPE: Let's not go into settlement discussions. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 14 THE DEPONENT: Hold on. It wasn't a settlement discussion. That was a threat. MR. PRINCIPE: Okay. THE DEPONENT: That was Marty O'Boyle telling me that if I didn't recant my sworn testimony that he was going to unleash his massive finances and stalk me to the ends of the earth. You know, if we're going to have conversations about the 2004 examination as they relate to my bankruptcy, I'm more than happy to answer the questions, but what he's attempting to do is to ask the questions that he wants to work this deal with, this whole -MR. PRINCIPE: Let's not get into the deal on the record. BY MR. O'BOYLE: Q. You're refusing to answer the question? A. Marty, as I said before and I'm going to say it for the last time. I will be more than happy to answer to the best of my ability any questions that you or any of my other creditors have regarding my finances. Q. Are you refusing to answer the question? A. Can you help me understand how that pertains to my finances? Q. You have counsel. He -- if your counsel 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 15 advises you that it doesn't and advises you to not answer the question, then I'll move on. MR. PRINCIPE: I'd like to see where it goes. Can we go off the record for a minute? Let me talk to him outside. (Recess from 2:03 p.m. to 2:08 p.m.) MR. O'BOYLE: Back on. BY MR. O'BOYLE: Q. Mr. Chandler, there's a question that is pending, and I would ask once again that you kindly answer. A. What's the question? (The preceding question was read by the court reporter.) BY MR. O'BOYLE: Q. So there's the question. A. That was a compound question. Which one do you want me to answer? MR. O'BOYLE: Okay. Can you read the question back again? (The preceding question was read by the court reporter.) BY MR. O'BOYLE: Q. Let's stop right there. How did you come to meet Mr. Sweetapple? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 16 A. Can I ask you to rephrase the question? Q. No. A. I don't understand the question. Q. Okay. Did you meet Mr. Sweetapple? A. I did. Q. How did you come to meet him? A. You're asking me the same question again. I don't understand the question. You're not willing to rephrase. Q. Were you in an airplane and that's where you met him? A. No. I drove. Is that how you -- how did I -how did I -- transportation-wise how did I go to meet him? I drove. Q. Well, how did -- how did you come to meet him? As an example, if you had told me you met President Obama I would say to you "how did you come to meet President Obama?" And I'm asking the same question about Mr. Sweetapple, and I don't think it's that difficult. MR. PRINCIPE: Objection; I don't think it pertains to a 2004 exam. A. I'm just asking that you rephrase the question. I don't know what you mean. That's why I said -- how did I come to meet him? I drove my car is the first thing that popped into my head, but frankly, I thought that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 17 sounded like a smartass answer until you said "well, did you take a plane?" I came to meet him in my car. BY MR. O'BOYLE: Q. Okay. And when you drive down the turnpike -as an example, you drive down the turnpike a lot, correct? A. I do not. Q. Okay. Where do you -- what's your main road that you drive on? MR. PRINCIPE: What is -- objection; that has nothing to do with his bankruptcy, where he drives. BY MR. O'BOYLE: Q. You may answer. A. I rarely drive. Q. Okay. But when you do drive you don't just meet people along the road when you're driving down the turnpike 95, 60, 75? A. When I was traveling -- actually, when I travel the roads I meet people frequently. Q. Okay. And did you meet Mr. Sweetapple when you were driving the roads? A. No. I drove to meet him. Q. Okay. And how did -- what -- how did you come to decide to drive to meet Mr. Sweetapple? A. He invited me to meet him. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 18 Q. Okay. And did he invite you for dinner? What did he invite you for? What purpose? A. To -- he wanted to ask me some questions. Q. And in what connection? How to make stew? What did he want to know? MR. PRINCIPE: Objection. Well, how is this relevant to the bankruptcy? You're not there yet. You're asking the questions before you get to a bankruptcy question. MR. O'BOYLE: I understand. MR. PRINCIPE: I'm asking. MR. O'BOYLE: I understand. MR. PRINCIPE: Or we're going to have to call the judge. MR. O'BOYLE: Well, he could refuse to answer. That'll be all right with me. MR. PRINCIPE: It's your call. I don't see it pertains to the bankruptcy. THE DEPONENT: I don't either. A. He asked me a lot of questions. BY MR. O'BOYLE: Q. Why did he ask you questions? A. I suppose he was looking for answers. Q. And the type questions he asked you, were they in connection with housing prices, food? What were they 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 19 in connection with? Tires? What were they in connection with? A. He asked me many questions. I couldn't tell you exactly -- what all the questions -- it was many, many months ago. Q. Uh-huh. A. It was over the course of several hours, as I recall. I -- and I don't know. The topics were various and sundry. Q. But he may have asked you about tires? A. I don't recall him asking me about tires. Q. Well, you just said you didn't know. A. Is there a question? Q. Uh-huh. A. What's the question? Q. Did he -- did you just say that you didn't know about tires? A. Can you read back what I said? THE COURT REPORTER: Which answer? An answer? Your answer? THE DEPONENT: Whatever it is he's asking me I said. MR. O'BOYLE: This is the one where I said tires, I think food. I don't remember exactly. (The preceding question was read by the court 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 20 reporter.) MR. O'BOYLE: And his response? (The preceding question was read by the court reporter.) BY MR. O'BOYLE: Q. Okay. A. So, no, according to the transcriptionist, I didn't say I don't know. That was your last question. Q. You have no idea why he summoned you down to southern Florida; is that correct? A. I have no idea what you're talking about. Q. Okay. Did he summon you to southern Florida? A. No, he did not. Q. I thought you said that he had you come down. A. I don't believe I said that. THE DEPONENT: Can you -MR. O'BOYLE: No, you don't have to. Just strike that. BY MR. O'BOYLE: Q. What possessed you to leave your home in Lakeland and meet Mr. -- well, first of all, where did you meet Mr. Sweetapple? A. I've already answered this question. Q. Okay. Well, can you answer it again? A. I've already answered your question. Asked and 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 21 answered. Move along. MR. O'BOYLE: Counsel? MR. PRINCIPE: Answer it again. A. I said Lakeland. BY MR. O'BOYLE: Q. Okay. You met -- you met him in Lakeland? A. Yes. Q. Okay. What possessed him to come to Lakeland? A. You'd have to ask him. Q. What induced him to come to Lakeland? A. You'd have to ask him. Q. Did you have any conversations with him before he came to Lakeland? A. I did. Q. And what were the conversations? What was the thrust of the conversations? A. About meeting in Lakeland. Q. And that's all? You had multiple conversations. What you're telling me -- and if I'm incorrect please correct me -- what you're telling me is the conversations that you had before his trip to Lakeland, all you spoke about was him coming to Lakeland; that's it, right? A. I'm sorry. If you're going to testify you need to be under oath. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 22 Q. It's a question. A. That wasn't a question. Q. It was. I said "right?" Question mark. A. I'm confused. Q. Okay. Mr. Sweetapple came to Lakeland, correct? A. Yes. Q. Okay. And he came to Lakeland to see you, correct? A. I don't know what all the reasons were for him coming to Lakeland. We met in Lakeland. Q. So he came to see you. I didn't say limited to coming to see you. I said he came to see you. A. Again, you're asking me about his motivations for traveling presumably. I can't tell you. I can tell you I met him in Lakeland. Q. Okay. And when you met him in Lakeland what happened? A. We talked. Q. And where did you meet? MR. PRINCIPE: Objection; I still don't see this line of questioning going towards a 2004 exam. MR. O'BOYLE: You will. MR. PRINCIPE: I want to know how it pertains to a 2004 exam. I don't want you to ask 37 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 23 questions, and then we decide that it doesn't pertain to a 2004 exam. It seems to me that you're fishing in response to some sort of lawsuit that's pending out there against you and some other entities. That's not what a 2004 exam is. MR. O'BOYLE: I'm aware. MR. PRINCIPE: And we're going to -- if we have to adjourn we will. Do you have any other questions that you know pertains to the bankruptcy? MR. O'BOYLE: Well, I believe that the questions I've been asking pertain to the bankruptcy; his schedules, his -MR. PRINCIPE: How does it pertain to the schedules? MR. O'BOYLE: Well, his -- his interaction with Sweet -- Sweetapple ties directly into CAFI, which is in his schedules. MR. PRINCIPE: CAFI is in the schedules because they're a disputed creditor in the case. He's under oath to list all claims that could possibly be out there against him. And that's why they're listed and you know that. MR. O'BOYLE: I understand, and I gave you my answer. And if you want to instruct him not to answer I understand. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 24 MR. PRINCIPE: What do you think? A. What was the question again? (The preceding question was read by the court reporter.) A. I don't understand what you mean by where did we meet. BY MR. O'BOYLE: Q. Okay. MR. PRINCIPE: Objection; how does that pertain to the bankruptcy because they met somewhere? Maybe they met in a tree, but I don't get that pertains to his bankruptcy and his financial condition; where they met. Now, there may be another question out there, but that's not one of them. MR. O'BOYLE: Yeah. Well, I'm getting -- I'm getting to where I want to go, but I think I need this foundation information, and I don't think that there is any reason in the world that I shouldn't get it. MR. PRINCIPE: Well, the objection's on the record. MR. O'BOYLE: Right. BY MR. O'BOYLE: Q. There's a question pending. MR. PRINCIPE: It's not relevant. Where did 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 25 you meet? THE DEPONENT: And I said I don't understand the question. BY MR. O'BOYLE: Q. You don't understand where you met means? Where did you meet? You don't understand what that means? A. I told you we met in Lakeland. Q. I understand. You met every corner in Lakeland? Every store in Lakeland? Every apartment in Lakeland? MR. PRINCIPE: Objection to the question; sarcasm. BY MR. O'BOYLE: Q. You met at all those places? A. That was a compound question. I don't know how to answer that last question you just asked me. Q. Okay. Did you meet on the corner of any streets in Lakeland? A. No. Q. Okay. Did you meet at the YMCA? A. No. Q. Did you meet at any department stores? MR. PRINCIPE: Objection to the line of questioning; it does not relate to the bankruptcy. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 You can answer. BY MR. O'BOYLE: Q. You may answer. A. No. Q. No. Where did you meet? A. Are you asking me for an address? Q. No. A. I don't understand what you're asking me for. I am asking you to instead of -Q. Did you meet at a lawyer's office? A. No. Q. Did you meet at a court reporter's office? A. Yes. Q. Okay. So now I think I'm understanding. Mr. Sweetapple called you and all he said -MR. PRINCIPE: Please ask a question. MR. O'BOYLE: Pardon? MR. PRINCIPE: Please ask a question. MR. O'BOYLE: I'm asking a question. BY MR. O'BOYLE: Q. Mr. Sweetapple called you and all he said was "I'm coming to Lakeland." And when he got up here you were surprised that he went to a court reporter's office; is that correct? A. That was a compound question. I don't know how 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 27 to answer it. Q. Okay. How did you end up -- did you know you were going to a court reporter's office before you got to the court reporter's office? A. In reference to my meeting with Bob Sweetapple? Q. Yes. A. Yes. Q. You knew? A. Yes. Q. How did you know? MR. PRINCIPE: Objection. How does that pertain to this bankruptcy? How does it pertain to CAFI? Well, how does it pertain to CAFI in the suit against him? A. Well, here's the other question I have. If it relates to the CAFI lawsuit are you representing CAFI? Why are you -- why do you have any standing to ask me any questions about my debt with -- the alleged debt with CAFI. I don't understand. BY MR. O'BOYLE: Q. When you take my deposition I'll answer that question, but meanwhile this is my deposition. A. Go ahead. Q. Okay. Well, I think I have a question on the table here. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 28 MR. PRINCIPE: And we've objected. A. And I said it was a compound question. BY MR. O'BOYLE: Q. Then I asked another question after that. MR. PRINCIPE: What was the last question he asked, please? (The preceding question was read by the court reporter.) A. I don't recall. BY MR. O'BOYLE: Q. You don't recall how you knew? A. Asked and answered. Q. No. I'm asking you how did you know? A. I said I didn't recall. MR. PRINCIPE: Then he did answer the question. A. And then you asked me again "you didn't recall?" No, you can't keep asking me the same questions over and over again. Q. Mr. Chandler, this is my deposition, sir. I'm not going to be lectured by you, nor am I going to be told what to do by you. If you want to leave, that's up to you. You're going to answer the questions that I'm entitled to ask. If you don't understand the question, I will be glad to take as much time as necessary to try to make it so you do understand it so that you could easily 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 29 answer it. That's my goal. A. Okay. Go ahead. If you'll do that I'm more than happy to participate. Q. Okay. Mr. Sweetapple came and he took a sworn statement, correct, from you? A. Yes. Q. Okay. If I would have come up would you have given me a sworn statement? A. I don't know. Q. Okay. A. I'm giving you -- I'm giving you -- I'm answering your questions under oath now. Q. This is a 2004 examination, as you pointed out. If I come up next week and ask you to meet me at a court reporter's office so that we could ask broader questions beyond the 2004 examination, similar to what you did with Mr. Sweetapple, you'd agree to that or not? A. I don't know. You've never asked me to. Q. I'm asking you now. MR. PRINCIPE: That's not a -- that's not a proper question for a deposition. Objection. BY MR. O'BOYLE: Q. You may answer. A. I don't know. Q. You don't know if you'd allow it? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 30 A. I don't know. Q. So you might and then again you might not, correct? A. Okay. Asked and answered twice. Q. Okay. Do you -- in your United States bankruptcy schedule -- this is for the current bankruptcy -- before I get into that, you had a previous bankruptcy, didn't you? A. Yes. Q. And -- excuse me -- what happened to that? A. I dismissed it. Q. You dismissed it? A. I believe that we -- my wife and I dismissed it with the help of our attorneys, as I recall. Q. Okay. Why would you dismiss it if you'd filed it? A. It was filed as -- as I recall, a Chapter 13. Q. A Chapter 13, you say? A. As I recall. Q. Okay. Would you kindly answer my question? A. Yeah. We filed a Chapter 13, and then when I left my job with Citizens Awareness Foundation, it was no longer possible for us to meet the agreed-upon payment structure with the court, so we dismissed the case. Q. And did you dismiss it immediately upon your 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 31 leaving Citizens? A. I don't know. Q. You don't know? A. I don't recall. Q. Okay. In your schedules you say "potential claim against Marty O'Boyle for slander." What is that claim and where did it emanate from? A. I'm sorry, that was a two-part question. One at a time. Q. Sure. What is that claim? A. For slander. Q. And what is the slander? A. False statements that I believe you made about me. Q. And what false statements do you believe that I made? A. I'd have to go back and give you some thought. I can't tell you off the top of my head. Q. So you don't know of any as you sit here? A. I'd have to give it some thought. There were so many. Q. Can you answer my question? A. I just did. Q. No, you didn't. A. I'm sorry you don't like the answers that I'm 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 32 giving you, but I answered the question. Q. No, you didn't. A. Move along. Q. Don't tell me what to do, Mr. Chandler. MR. PRINCIPE: Don't say that. BY MR. O'BOYLE: Q. Don't do it. MR. O'BOYLE: Would you read my question back, young lady? THE COURT REPORTER: Sure. (The preceding question was read by the court reporter.) BY MR. O'BOYLE: Q. I don't think you answered my question. A. I've answered your question. MR. O'BOYLE: Okay. Can you read my question back one more time, just my question? (The preceding question was read by the court reporter.) MR. O'BOYLE: I think the one after that. What was his answer there? (The preceding question was read by the court reporter.) BY MR. O'BOYLE: Q. Can you tell me any false statements that I 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 33 made about you. A. Yeah. Your nonsensical claim that I had stole money from CAFI. Q. And I made that statement directly to you or to who? A. No. I don't think you made that statement directly to me. Q. Who did I make it to? A. I don't know off the top of my head. Q. How do you know that I made it? A. Well, let's see. I saw a videotaped deposition that you participated in where you made that statement under oath and on the record. Q. And how would you have come to see a videotaped deposition? A. YouTube. Q. YouTube? A. I think it was YouTube. It was online someplace. Q. I see. Okay. And is that the only slander that you assert? A. No. I need to go back and consult my notes. I'm confident there are more, but without going back and looking at my notes it would be difficult for me to -Q. How could you say you're confident that there's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 34 more? If you can't remember them how could you say you're confident there's more? A. I'm confident that there are more. I don't remember all of them off the top of my head. I would want to go back and look at my notes. Q. And if I was asking for all of them, I might understand that, but I'm not. What other ones are there? Give me one. Give me three. Give me five. Give me 50; whatever you -- whatever you can remember. A. I've answered your question. Q. So you can't remember any; is that correct? MR. PRINCIPE: He gave you one. MR. O'BOYLE: Besides the one. A. I've already mentioned one. I've already said that I would need to give it more thought. I've also said that I would need to consult my notes. I've said that I can't recall each of them; there are so many of them. So I think I've answered that question over and over and over again. BY MR. O'BOYLE: Q. And I believe that's what you think, but I don't -- as far as I'm concerned, your answer is unsatisfactory. What I want to know is, you have notes showing a plethora of slanders. There's so many of them you can't remember. Not one? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 35 A. I've already mentioned one in particular. Q. No. No. No. Not a one in addition to -A. Well, that would be more than one. Q. One in addition to. Well, I'm not going to argue with you about more than one or whatever. I'm asking, are there any others besides the one that you told me about, which was in a litigation deposition? A. I'm confident there are. I would need to consult my notes to refresh my memory about the particulars of them, and since I'm under oath I want to be precise in my answers. Q. Okay. Do you have any other claims against me? A. None that come to mind. Q. Is that a yes or is that a no? A. It's not a question that begs a yes-or-no answer. None that come to mind. I don't know that there are. I'm not prepared to say that there aren't any. There may be -- there may be claims that have not yet presented themselves. Q. Well, let me ask you this then. MR. PRINCIPE: Hang on. Just for clarification, can you put a time frame again on it? MR. O'BOYLE: On what? MR. PRINCIPE: On the question you're asking; is there a claim out there because - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 36 MR. O'BOYLE: As of today. MR. PRINCIPE: As of today. Do you know of any -A. None that I -- none that I can recall. None that I'm immediately aware of. BY MR. O'BOYLE: Q. Okay. Now, Mr. Chandler, I am going to read to you on page 25 of 47 of your filing the declaration concerning debtors schedules. MR. PRINCIPE: Go ahead. BY MR. O'BOYLE: Q. "I declare under penalty of perjury that I have read the foregoing summary and schedules consisting of 24 sheets and that they are true and correct to the best of my knowledge, information, and belief." Where are the other claims that you have or did you perjure yourself? A. I did not perjure myself. Q. Well, shouldn't they be on the bankruptcy? A. My answer was none that I'm aware of; none that immediately present themselves to me. Off the top of my head I can't think of any. That's not to say -- let me be clear for the record -- that's not to say as I've already indicated there may be unknown causes of action, things that I don't know about that's entirely possible given your lack of character and your willingness to bend 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 37 the truth. To the best of my knowledge, which is what this says, this is all that's there. There's nothing else that I'm aware of. That's not to say that there aren't others -Q. Okay. A. -- that I may not be aware of. MR. PRINCIPE: Let me remind you, though, this is as of that date of filing, so you're asking about through today. MR. O'BOYLE: I understand. MR. PRINCIPE: So there may be, as we call it, a post-petition claim. I don't know. He's testifying that he doesn't know about it. MR. O'BOYLE: And I -- and I understand. But the day that he filled this out -BY MR. O'BOYLE: Q. -- this was the only potential claim that you had against me, correct? A. That I was aware of, yes. Q. Okay. Well, of course that you're aware of. A. What I said, it's entirely possible that there could be all manner of unknown claims. I have no idea. Q. But you know of none? A. That's what I've said. I've already said that. Q. Okay. No. You said before you had a list of 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 38 them on a piece of paper. MR. PRINCIPE: No, that's not -A. No, I didn't. MR. PRINCIPE: That all pertains to the slander claim, which is listed on the schedules. BY MR. O'BOYLE: Q. Okay. A. You asked me for an example of slander. I gave you one example. You asked me for all the other ones. I don't know. I got to look at my notes. I have no idea. Q. Okay. When -- how many times have you seen me since 12/17/14? MR. PRINCIPE: That's since you filed the Chapter 7. A. I think this is our second meeting, as I recall. BY MR. O'BOYLE: Q. Okay. And our first one was across the hall here; am I correct? A. I think we met here, but -Q. Yeah. Here and then we went across the hall, if I recall. A. Yeah, in the room where you threatened me, yes. You threatened me that if I didn't recant my sworn testimony that you were going to do all kinds of bad 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 39 things to me and my family. Q. Your attorney was there? A. He was, as was my wife. Q. If you want to assert that, you make your assertions. A. I already have. Yes, you threatened me. You threatened me that if I didn't recant my sworn testimony that you're very wealthy and you were going to spend whatever it takes to wreck my life. Yes, I am asserting that. Q. Do you have a problem with the truth? You're not a very honest man, are you? A. I think I am a truthful person. Q. Well, what you just said was not truthful at all; not even close to being truthful. MR. PRINCIPE: Is that a question? MR. O'BOYLE: Yes. A. How is that a question? MR. PRINCIPE: Phrase it in a question. MR. O'BOYLE: I just did. BY MR. O'BOYLE: Q. Is it? A. You did threaten me. You threatened me. Q. When did I threaten you? A. I'm sorry? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 40 Q. When did I threaten you? A. I've already answered this question. Across the hall you threatened me. One of the first things out of your mouth was that if I didn't recant my sworn testimony, that you were very wealthy and you were going to spend all kinds of money to just keep coming after me, if I didn't recant my sworn testimony. Q. Mr. Chandler, have you ever been arrested? A. I have. Q. For what? A. For solicitation of prostitution in 1990, December. Q. Now, would you say that as a result you have good character? A. I think like all people I'm flawed. Q. Well, that's true. I agree with you, but can you answer my question? A. I did just answer the question. Q. No. You said -- I said, do you think you have good character and you said like all people you're flawed. My question was, do you think you have good character? A. I think like all people I have character flaws. Q. Okay. Does that fit into the good character or the bad character? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 41 A. I believe in the duality in man. I also believe in the total depravity of man. I believe that all men are capable of the most heinous acts, and even the most heinous men are capable of extraordinary acts of generosity and kindness. I think we are made of the same stuff that Mother Teresa is made of and the same stuff that Charles Manson is made of. So I think we all have the ability to do good things and bad things, and I think that as far as my character is concerned, I'm capable of horrible things, and I'm capable of extraordinarily good things, just like you and just like everyone else. Q. How do you know you're capable of horrible things; because of what you did to my son? MR. PRINCIPE: How's that -- objection; how does that pertain to the bankruptcy? Objection. Strongly objecting. A. I don't know what you're referring to when you say what I did to your son. MR. PRINCIPE: Don't answer. Let him ask another question. BY MR. O'BOYLE: Q. So your potential claim against me for slander is limited to a litigation deposition on you said you think it's YouTube and across the hall that I said 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 42 something about I have a lot of money or something? A. No. Q. No, you didn't say that? A. No. Q. What did you say? A. At what point in this conversation? Q. Well, let's start -MR. PRINCIPE: He's asking if there's any more instances again of slander other than the one -A. I think that there probably are. And just so we're clear, in filling out the paperwork for the bankruptcy -- I'm not an attorney. I don't purport to be an attorney. I'm not trying to draw any legal conclusions. The question that was presented to me in the filing paperwork and by the trustee is, "Are you aware of any -- is there anybody we can sue on behalf of the -- of the estate of the bankruptcy?" And my response is, "This is the only thing that I can think of; it's the only one I know of. I'm not in a position to draw any legal conclusions about that." I'm trying to be as helpful to the bankruptcy trustee as I possibly can by disclosing everything that she has asked for and everything that the court has asked for. BY MR. O'BOYLE: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 43 Q. Okay. Besides slander do you have any other claims against me? A. I've already answered this question. Q. Okay. MR. PRINCIPE: Objection; he has answered this. BY MR. O'BOYLE: Q. Okay. Except for the claims -- the claim for slander, line 21 on page -MR. PRINCIPE: What page are you on? MR. O'BOYLE: 7. BY MR. O'BOYLE: Q. -- do you have any claims against anyone in Palm Beach or Broward County? A. During what time frame? Q. Now. A. Not that I'm aware of. Q. Okay. A. None that come to mind. Q. Huh? A. None that come to mind. Q. All right. Okay. So there may be claims; is that correct? A. I don't know. Q. You don't know if there may be? There's maybe and then there's maybe not. And I don't know of anything 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 44 else besides those two. And you don't know; is that correct? A. I've already answered the question. Q. Okay. I'll accept that answer. How did you get here today? A. I drove. Q. What did you drive? A. A car. Q. What kind of car? A. Daewoo. Q. And what year is the Daewoo? A. I have no idea. Q. Okay. Who owns the Daewoo; whatever it's called? A. One of my sons does. Q. I see. And what son would that be? A. Samuel. Q. Samuel. And you have a potential counterclaim against Citizens Awareness Foundation, Inc., for vexatious litigation, am I correct, at least that's on your schedule? I shouldn't say you have. A. Yeah. I think -- I think the way I would characterize it is that the estate or the bankruptcy does. I don't think that I personally do any longer because I filed for bankruptcy. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 45 Q. But when you filled this out -A. Yeah. Q. What is it about? You filled it out under oath? A. Yeah. The nonsensical lawsuit that Citizens Awareness Foundation has filed against me. Q. And it's nonsensical based on? A. This has nothing to do with the bankruptcy. Again, my concern about answering-MR. PRINCIPE: That's -- let me interject. I think that that does pertain to the bankruptcy, that lawsuit, because you've listed it and you've listed it -THE DEPONENT: The bankruptcy does -- I agree -- but since it's pending litigation outside of the bankruptcy, the 2004 exam is not supposed to be used as a means of gaining an adversarial advantage, which -MR. PRINCIPE: I get that. Ask your question again. Ask your question again. (The preceding question was read by the court reporter.) MR. PRINCIPE: The one before that. (The preceding question was read by the court reporter.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 46 THE DEPONENT: The last question was why was a nonsensical -- it's a meritless lawsuit. There's no merit to it. BY MR. O'BOYLE: Q. And who divined that there was no merit to it? A. I have reviewed it, and I have sought legal counsel and the conclusion was unanimous that it is without merit. Q. What legal counsel did you consult? A. I'm not under obligation to answer any questions about communications with me and my legal counsel or even who my legal counsel may be. MR. O'BOYLE: Counsel? MR. PRINCIPE: He can ask you who you contacted, but he can't ask you the discussions. A. A number of attorneys. BY MR. O'BOYLE: Q. What -- can you -- I'd like the names of the -of all of them. A. I couldn't name all of them. I'd have to go back and look at my notes. Q. Of course. I recognize that you have to look at your notes to answer most questions, but you don't remember any of them? A. You asked -- you said you wanted me to name all 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 47 of them. Q. I just said you don't remember any of them? A. I do remember some of them. Q. Can I have their names, please? A. Greg Thomas; Ana Clara Anderson. Q. I'm sorry; Ana? A. Ana Clara Anderson. And I'd have to -- there were others. Q. Okay. But that's all you know about? MR. PRINCIPE: That's not what he answered. MR. O'BOYLE: I just said "that's all you know about today." MR. PRINCIPE: Okay. That's it. BY MR. O'BOYLE: Q. Correct? A. I wouldn't say that's all I know about them. I'm saying I would need to refresh my memory by looking at my notes. Q. Okay. This is all you recall today? A. With certainty, yes. Q. Okay. Now, was Sherry Hopkins one of the lawyers you consulted? A. I don't believe so. Q. Do you know Sherry Hopkins? A. That name's familiar to me. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 48 Q. Can you place her? A. If I'm not mistaken, she -- there's a woman named Sherry Hopkins who represented the City of St. Cloud. Q. Go ahead. MR. PRINCIPE: I think he answered your question. MR. O'BOYLE: Okay. BY MR. O'BOYLE: Q. Now, Mr. Chandler -A. Hold on a minute. MR. PRINCIPE: Go off the record for a second. (Recess from 2:48 p.m. to 3 p.m.) THE COURT REPORTER: Back on. BY MR. O'BOYLE: Q. Mr. Chandler, you did receive our notice for the Rule 2004 examination; I assume you or your attorney, Would that be correct? A. For today? Q. Yeah. Well, no, not for today because you've been changing it. MR. DESOUZA: There was a new one for today. MR. O'BOYLE: Pardon? A. I didn't change it. The judge didn't allow you to do the last one. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 49 MR. DESOUZA: There was one for today. MR. O'BOYLE: There was one for today? MR. PRINCIPE: Yeah. A. I haven't seen the notice, but I'm here. BY MR. O'BOYLE: Q. Okay. MR. PRINCIPE: The certificate of service says it was mailed to him. MR. O'BOYLE: That's good. BY MR. O'BOYLE: Q. Okay. In connection with your -- I guess we'll call it a subpoena. MR. PRINCIPE: It's not a subpoena. BY MR. O'BOYLE: Q. Okay. The notice for the 2004 deposition -examination, you were to bring multiple documents. And I would like for you to give them to me now. MR. PRINCIPE: I think we've provided them to Mr. Desouza. MR. O'BOYLE: Well, that's Mr. Desouza; that's not me. MR. PRINCIPE: Well, if you want to take a look at them, they're here. We'll give them to you. Do I have to go through that hoop to hand it to you? MR. O'BOYLE: I don't know. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 50 MR. DESOUZA: I don't know if it'll open on your computer. It won't open on mine. MR. O'BOYLE: It won't open on mine either. We have the same problem. So unless you can give them to us -- I mean, you can't give us a -Mr. Principe, you can't give us a drive and it doesn't work on our computers and say that's what you're getting. MR. PRINCIPE: Well, we're not saying that. MR. O'BOYLE: What are you saying? MR. PRINCIPE: I didn't know it didn't open until we got here. He will produce it. He will produce it. He doesn't have a problem. A. So we can answer Mr. O' Boyle's question, why don't you bring that down here and let me show you right now -- let me show you that this actually works. Would you like to step around here, Mr. O'Boyle? BY MR. O'BOYLE: Q. No. A. I'll be happy to show you. Q. No, because we don't have -MR. PRINCIPE: Let's go off the record real quick. THE DEPONENT: No. We're on the record. Dan, come on down here. I want you to see this. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 51 MR. O'BOYLE: We're going off the record. (Discussion off the record.) MR. PRINCIPE: Let's go back on the record. A. And there is the hard drive, and that's everything that's on there. And you'll see that there's -- it's a 2 terabyte drive, so it's almost 1.1 terabytes of data. There are -- yeah, 1.3 terabytes of data. MR. DESOUZA: Is this drive any different than the last one that you produced at the prior deposition, Joel? THE DEPONENT: Well, I don't know what make or model that was. MR. DESOUZA: Well, I mean, the context. Whether the drive is different -THE DEPONENT: There are additional documents because additional documents were requested, and here they are. I don't know who wants it, but Judge May said you guys are doing all this together, so there's one drive, which I still need to be reimbursed for. MR. DESOUZA: Thank you. MR. O'BOYLE: We're on the record? THE COURT REPORTER: Yes. BY MR. O'BOYLE: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 52 Q. Okay. Mr. Chandler, as far as the documents that you were supposed to produce, you have not produced those documents, as I understand it, but rather you have produced some type of a drive that could be appended to a computer. And Mr. Desouza reports that he does not have an Apple computer and that drive will not work on his computer. So can you give us hard copies, please? MR. PRINCIPE: Today? MR. O'BOYLE: Yeah. Well, we're here to take a -MR. PRINCIPE: How are we going to produce that? MR. O'BOYLE: Pardon? MR. PRINCIPE: He was assuming that he had -you had the documents right here. MR. O'BOYLE: Well, he can assume all he wants. MR. PRINCIPE: So I guess the answer is we can't produce it right now. A. I could -- I would not be able to do that because there are thousands and thousands and thousands and thousands and thousands and thousands and thousands of pages of documents on the hard drive. BY MR. O'BOYLE: Q. And this is one subpoena, and that's all we need to get those thousands and thousands and thousands 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 53 and thousands and thousands -A. And I have provided them to you. Q. No, you haven't. A. Yes, I have. They're right there. If you'd like to inspect them, I've offered to let you inspect them on my computer. You can open them up on your computer. MR. PRINCIPE: You can open them up on his. MR. O'BOYLE: Yeah, but there are thousands and thousands and thousands -- and I don't want to -- I don't want to look at his computer, nor do I want him looking at mine. A. I'm sorry that I use a Mac and that you use a PC. BY MR. O'BOYLE: Q. You shouldn't be sorry. A. It's not my problem. Q. You shouldn't be sorry. What you should have done is produced hard copies like everybody else in the world, and then we wouldn't be having this discussion. So let's do this. A. Was that a question or are you just testifying again? Q. Any and all documents provided to the Chapter 7 trustee and/or the United States trustee in connection 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 54 with debtor's Chapter 7 case, tell me what they are. MR. PRINCIPE: What have you provided to the Chapter 7 trustee? A. I couldn't tell you off the top of my head. Whatever paperwork my attorney's asked me to produce, and I've provided everything that the court's asked me to provide and to the best of my knowledge all those documents were -- have been placed on the hard drive that I provided. MR. PRINCIPE: I can go specifically. BY MR. O'BOYLE: Q. Any and all documents provided to the Chapter 7 trustee and/or the United States trustee in connection with the debtor's Chapter 7 case. If you have the -MR. O'BOYLE: Dan, maybe you could give Joel the hard drive, and he can tell me what documents he has. A. They're on the hard drive. I couldn't tell you. BY MR. O'BOYLE: Q. Okay. We can't get them off the hard drive, and you don't know what's on the hard drive and you had an obligation to produce them. A. And I did produce them. Q. Where are they? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 55 A. On the hard drive. MR. O'BOYLE: Well, Dan, you can't get them, can you? MR. DESOUZA: It does not open on my laptop. MR. O'BOYLE: Okay. MR. PRINCIPE: Or you can look at them on his. MR. O'BOYLE: Ask him what documents. A. There are so many documents. I don't know off the top of my head which document. I don't understand -I don't understand -- yeah, I don't remember which documents exactly I gave the trustee. Everything that I've been asked to produce to the best of my ability and to the best of my knowledge I've put on that hard drive. If for some reason -- let me just be clear just so everybody understands -- the hard drive is encrypted. I'm happy to provide the password. It's "whitepeachestastegood"; all one word; lower case. White peaches taste good. I happened to be eating white peaches at the time that I did that. MR. DESOUZA: It's a true statement. A. If for some reason you are unable to access those because you don't have access to an Apple machine -- I don't have access to a PC, so I don't know what to do there. I would be more than happy to try to make some reasonable accomodation to -- if necessary to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 56 reformat the hard drive, if that would help or whatever. I'm happy to provide all the documents there, most of which have been provided previously to CAFI. I'm happy to give them to you. I have given them to you. If you would like me to help you change the format of them, I'm happy to try to make some reasonable accomodation to do that, but the records that were requested were so voluminous asking me to pinpoint one particular or even a few records would be very difficult. BY MR. O'BOYLE: Q. Would you kindly tell me what documents you have in response to number 1, any and all documents provided to the chapter 7 trustee and/or United States trustee in connection with debtor's Chapter 7 case? A. Yeah. All the documents I gave the trustee are on there. Q. Well, but you're supposed to produce them to us, not the trustee. A. Okay. One last time. I have produced them on a hard drive. If you-all are having some difficulty to getting those, I'm happy to try to work with you to make them more accessible. It seems that the issue is I use a Mac and you use a PC. Most of the documents -- a lot of them are PDFs, which shouldn't be an issue. I'm certainly happy 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 57 to try to work -- and Dan can tell you when I produced documents previously for CAFI, I was very happy to try to make accommodations to make sure he'd get them. I have produced the records. If you want me to try to work with you to make them more accessible, I'm happy to do that. MR. O'BOYLE: We're going to have to come back to finish Mr. Chandler's. MR. PRINCIPE: That's fine. I don't have a problem with that. Let me go off the record real quick. Let me go off the record. MR. O'BOYLE: Stay on the record. And I would expect when I come back to have 36 files or piles or -MR. PRINCIPE: You're not going to get them because I've objected to some of them. MR. O'BOYLE: Okay. The ones you objected to -MR. PRINCIPE: And Mr. Gomez and I talked about it and we were going to argue -- not argue, but talk about what should be and what shouldn't be. So subject to that objection, we're not producing it yet until we can work it out. Now, if Mr. Gomez is not working -- is not working for you, then you and I need to go over the objection that was actually put in the protective 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 58 order; and remember, Mr. Gomez, who was representing you at that time indicated to the judge that we're going to try to work out the document request. MR. O'BOYLE: Right. And I don't know what occurred. I mean, I just don't know. MR. PRINCIPE: You were there. MR. O'BOYLE: Work out the document request? MR. PRINCIPE: Well, that's what I'm saying, but it's in the objection. Now, I can ask him if you'd like me to help you along here, you know, are the tax returns that you provided to the trustee on that document? THE DEPONENT: I believe they are, yeah. MR. PRINCIPE: Those type of questions he might be able to answer. MR. O'BOYLE: Okay. Well, let's look at them. MR. PRINCIPE: Can you pull up your tax returns? THE DEPONENT: I really don't want them going over my -- playing on my computer. I'm happy -- I'd be happy to -- if we can accommodate putting them on the screen, I'd be happy to do that. I'd be happy to reformat that. MR. PRINCIPE: Can you put it on the screen? THE DEPONENT: I don't know whether we can or 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 59 not. My point is I'm happy to help you get access to them. I'm sorry that you don't have the ability to open a hard drive that was formatted on a Mac. I don't own a PC. MR. DESOUZA: Let's go off the record for two minutes. Marty, come over here. MR. O'BOYLE: Okay. (Recess from 3:12 p.m. to 3:21 p.m.) BY MR. O'BOYLE: Q. Joe, I'm not going to ask any more questions about this today, because we wasted already too much time. So let's move along, if we can. MR. PRINCIPE: And we'll agree you can take it once we get the docs like that, and then we'll iron out our objections. I don't have a problem. MR. O'BOYLE: That's fine, Frank. Are we back on the record? THE COURT REPORTER: Yes, sir, we were. MR. O'BOYLE: Good. BY MR. O'BOYLE: Q. Mr. Chandler, I'm looking again at your schedule in connection with the bankruptcy that you filed that is currently pending, and I see on creditors holding unsecured -- unsecured nonpriority claims that there is - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 60 MR. PRINCIPE: What page number? MR. O'BOYLE: It's page 15 of 47. MR. PRINCIPE: Thank you, sir. BY MR. O'BOYLE: Q. And it's in connection with Citizens Awareness Foundation, and it says "debtor disputes that he owes any money to this creditor." Do you dispute that you owe any money to the creditor? A. Yes. Q. And on what basis do you dispute that you owe -- don't owe any money to that creditor? A. I don't owe them any money. Q. On what basis I said? A. The truth and the facts. Q. And what are the facts that would show you don't owe them any money? A. I didn't borrow any money from them. Q. That doesn't mean you don't owe them any money? MR. PRINCIPE: Is that a question? MR. O'BOYLE: Yes. BY MR. O'BOYLE: Q. That doesn't mean -- does it? A. I didn't borrow any money from them. I don't have anything I would be -- I don't see how I owe them any money. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 61 Q. Okay. But as far as factually, can you tell me why you don't owe them any money? A. I'd have to go back and review my notes, in particular the motion to dismiss that I filed in connection with that case. Q. Now, several times today you've referred to your notes. A. Uh-huh. Q. Would you kindly bring them with you tomorrow? A. No, I won't. MR. O'BOYLE: Counsel? MR. PRINCIPE: It hasn't been requested. Have you requested it? MR. O'BOYLE: I'm not sure I didn't reread -the documents we asked for were from March, so I haven't reread them. MR. PRINCIPE: Yeah. If you ask and we agree, then -- but right now I don't know what documents or what frame it is. As long as it pertains to the bankruptcy or anything else, I wouldn't have any objection, but I don't know if he can get it here by tomorrow. You say can he get them here by tomorrow? MR. O'BOYLE: Well, they're in his notes, which they're in his possession. And I can't imagine that it's - 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 62 MR. PRINCIPE: But part of it is -- and I don't know -- I'm not speaking for you, but part of it would be his notes may be his motion to dismiss. MR. O'BOYLE: Motion to dismiss? MR. PRINCIPE: He has filed a motion to dismiss, my understanding, that CAFI claim. MR. O'BOYLE: Okay. MR. PRINCIPE: And that's what he's saying. Is that part of your -THE DEPONENT: That's what I'm saying. I said I filed a motion to dismiss. MR. O'BOYLE: I just want to be clear. That may not be a no, but it may be something that -THE DEPONENT: There are certainly, you know, mental impressions that I wrote down in preparation for that, which certainly are not subject to disclosure. MR. O'BOYLE: Counsel? MR. PRINCIPE: I agree. MR. O'BOYLE: That mental impressions are not subject to disclosure? MR. PRINCIPE: I think they are, but -A. As I'm acting as my own counsel, no, they're not. BY MR. O'BOYLE: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 63 Q. Well, you're not acting as your own counsel here. A. In that lawsuit I am. Q. Not here. A. In that lawsuit -- and let me be clear. In that lawsuit I am acting as my own counsel. I am not obliged to -- unless Judge May tells me otherwise, I'm not obliged to disclose every solitary note that I've made or mental impression that I've created in preparation for legal pleadings in a case that are beyond the scope of this bankruptcy. MR. O'BOYLE: One second, please. MR. PRINCIPE: If you request it, then we'll take a look at it. And then if there's an objection, we'll make an objection. A. And by the way, many of the notes that I'm referring to are on the hard drive that I've provided to you. MR. O'BOYLE: Please bear with me for half a minute here. MR. PRINCIPE: Sure. Do you know what's on that hard drive? Go off the record real quick. (Discussion off the record.) MR. O'BOYLE: Back on the record. BY MR. O'BOYLE: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 64 Q. Mr. Chandler, the summary of schedules that you and Mrs. Chandler signed under oath, are they true or were they true and correct on the day you signed them? A. I believe that they were, yes. Q. Is that a yes or a no? A. I believe that they were, yes. Q. Okay. So they might not have been? MR. PRINCIPE: I think he answered the question. MR. O'BOYLE: That's another question. BY MR. O'BOYLE: Q. Is that correct? A. I signed them under penalty of perjury that they are true to the best of my knowledge, yes. I believe that they are true. Q. Okay. The signature line doesn't say to the best of your knowledge, and that would be on page 34 of 37 -- 47, I'm sorry. A. I'm sorry, which page? Q. 34. A. Yes. I attested that they are true and correct. I believe that I answered that correctly. Q. Okay. So that is a correct statement? A. Yes. I believe that to be true, yes. Q. And your signature where it says -- I'm going 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 65 to abbreviate -- that they are true and correct, that is a correct statement, right? A. Yes. I believe that it is. Q. Okay. And it was a correct statement when you signed it; is that correct? A. Yes. Q. Okay. Tell me about CAFI. A. I'm sorry? Q. Tell me about CAFI. MR. PRINCIPE: Can you narrow the question? MR. O'BOYLE: Sure. BY MR. O'BOYLE: Q. What do you know about CAFI? MR. PRINCIPE: Again, in what context and can you narrow it again? Do you have a specific question? BY MR. O'BOYLE: Q. Yeah. What do you know about CAFI? MR. PRINCIPE: Well, no; a specific question; not a broad question. There's two different things. MR. O'BOYLE: Well -MR. PRINCIPE: Because if you ask a broad question and he answers something, you're going to ask him another question because it didn't pertain to the question. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 66 MR. O'BOYLE: But if I asked narrow questions, Frank, I may ask him 50 questions, and I'm trying to avoid that. A. When you say CAFI what do you mean? BY MR. O'BOYLE: Q. Same thing you mean when you say CAFI. A. How could you possibly know what I mean? Q. Well -A. Are we talking about the Citizens Awareness Foundation, Inc., is that what we're talking about? Q. Yes. A. Okay. Just want to be sure that that's what we're talking about. Q. Yes; same. A. Asking me what I know about it is just extraordinarily broad. I wouldn't even know where to begin. Q. Well, just try. MR. PRINCIPE: Tell him what you think about CAFI. A. Yeah. Citizens Awareness Foundation was created in I want to say it was January of 2014, I believe. It was a corporation that I worked for for a few months. It was based in Deerfield Beach. MR. PRINCIPE: You can keep going. He asked 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 67 you the question what do you know; keep going. A. I became involved with Citizens Awareness Foundation after you invited me down to your home in south Florida, and we met and talked about you creating a foundation -- funding a foundation. We talked about the possibility of me working for the foundation. We talked back and forth over the course of several days about what that might look like, the particulars about what that employment would involve, as far as compensation and job responsibilities. It was created as a corporation I believe it was on -- I want to say January 27, 2014, but I'm not certain of that. And I went to work for the foundation literally as it was created. And I worked as the executive director. I was hired by you, and I worked there until I think it was June 30th of 2014 when I resigned. BY MR. O'BOYLE: Q. During the time that you were with CAFI -well, strike that. The agreement that you had with CAFI was called a memorandum of understanding; am I correct? A. Yes. Q. Okay. And that memorandum of understanding was prepared by who? A. I prepared it at your direction. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 68 Q. Okay. And when you prepared it you were quite satisfied with it, were you not? A. I had preferred to actually have an employment contract and you didn't want to do that. And I think as a good way -- by way of compromise, we agreed that we agreed to do a memorandum of understanding. And, again, I'd have to go back and check my e-mails, but, as I recall, we sent back and forth a couple of different versions, and it was the compromised version that we ultimately agreed to. Q. Have you ever said that you prepared it? A. Yeah. I believe I have. Q. Okay. You made several statements in writing and otherwise that you were supposed to be the only person who had, for lack a better way of saying it, the say in CAFI; am I correct? A. No. I don't think that would be accurate. Q. Okay. So you're saying -- well, then tell me what is accurate. A. About what? Q. What I just said. A. You just asked me if that was accurate. It's not accurate. I don't believe your characterization is true. I don't believe that's anything that I've said. Q. Okay. So what would be accurate? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 69 A. About what? Q. What we just spoke about. A. You asked me if it's accurate. I said it's not accurate. Q. And I said what would be accurate? A. About what? Q. About the -- what's it called -- the memorandum of understanding. A. What would be accurate about it? Q. Uh-huh. MR. PRINCIPE: Can you go back and read the statement that he made and then he said "no, it's not accurate" so he understands it, please? THE COURT REPORTER: Sure. (The preceding question was read by the court reporter.) BY MR. O'BOYLE: Q. What was compromised from the first draft that you prepared to the final draft? What was compromised? A. I'd have to go back and compare them. I couldn't tell you off the top of my head. Q. Okay. Do you remember anything that was compromised? A. I'd have to go back and compare them. Q. Okay. And do you -- do you deny that you said 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 70 that you were supposed to be in complete control of CAFI? A. I don't recall ever saying that. Q. Okay. But if I can show you that you did, you'd agree that that was a true statement because you're an honest man, correct? A. I don't recall having said that. I don't recall uttering those exact words. Q. Oh, I didn't say exact words; in concept. MR. PRINCIPE: Define "concept." MR. O'BOYLE: Generally stated. A. I don't believe that I've ever uttered that, not those words. BY MR. O'BOYLE: Q. Again, I didn't say those words. A. Well, what words -- you're asking if I said certain things. Without knowing what exact words you're asking me I said, I couldn't begin to tell you whether -I don't recall ever using those words. The exact words in the context would certainly have some bearing on my recollection, I'm sure. Q. Okay. Did you ever prepare a timeline? MR. PRINCIPE: For what? MR. O'BOYLE: I'm going to say for his employment with CAFI, but I don't know -- I think that works. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 71 A. I don't recall ever preparing any timelines for CAFI. As it relates to when I was employed with CAFI, I don't recall. BY MR. O'BOYLE: Q. I didn't say when it relates to -- in connection with CAFI. I didn't say for CAFI, and I didn't say during -- while you were there and so forth. A. I prepared a timeline in preparation for a conversation that I had with Bob Sweetapple relating to my employment with CAFI, yes. Q. Why would you do that? A. I find timelines to be helpful. They're a great way for me personally to refresh my memory and to put things in context. Sometimes it's helpful to visualize things in chronological order. Q. But why would you prepare in connection with your meeting with Bob Sweetapple? A. In order to refresh my memory about the conversation I anticipated we were going to have. Q. How did you know you were going to have conversations regarding the timeline? A. Well, I don't think we're going to have conversations about the timeline. I prepared the timeline as a way of refreshing my memory about the events that unfolded prior to, during, and subsequent to 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 72 my employment with CAFI. MR. O'BOYLE: Okay. Can you mark this as an Exhibit, please? THE DEPONENT: Sure. 1? MR. O'BOYLE: Yeah. Exhibit 1, yeah. (Exhibit 1 marked for identification.) MR. PRINCIPE: Is it a composite or is it just one exhibit? MR. O'BOYLE: Just one. A. Let me take a look at that real quick. BY MR. O'BOYLE: Q. Joe, why don't you let Frank look at it because I'm going to leave it with you? A. Are we going to talk about this? Q. Yes, we are. A. Well, then let me just flip through it real quick. I don't need to read every word of it. Q. All right. Go ahead. A. Okay. Go ahead. Q. Okay. You prepared that for Mr. Sweetapple? A. I don't know if I prepared that. I prepared a timeline. I couldn't vouch for that. I'd have to go through and actually compare that to what I had in my records, but -Q. Okay. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 73 A. -- I did prepare a timeline that that looks familiar. I can't verify that that's a true -Q. How could you verify it? A. I'd have to compare it to the documents that are in my notes and the documents that I've already provided to you on the hard drive. The timeline that I prepared is on the hard drive. Q. Okay. But you would agree that the information that's in there came generally from you? There may be something that might have been changed, but generally from you, correct? A. In the timeline that I prepared. Q. Yeah. But if you looked at that you would recognize a lot of the entries, wouldn't you, or would you recognize nothing? A. I said that it looks -- it looks familiar to me, but I cannot say with certainty without taking a lot of time right now to compare them. Q. Okay. A. I cannot vouch that what you've provided as an exhibit is what you're purporting it to be. I presume it is, but I don't know that. I did prepare a timeline. MR. O'BOYLE: Mr. Principe, if you would when you're finished looking at it, give that to Mr. Chandler and let him read it and then you can 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 74 tell me that what in that timeline you did not prepare, because you certainly recognize your own language. MR. PRINCIPE: Those questions do pertain to CAFI's lawsuit, correct, that you're going to ask and they're relevant to a 2004 exam? MR. O'BOYLE: They're relevant to a 2004 exam. They're relevant to CAFI. They're relevant to Gulfstream. They're relevant to Sweetapple. MR. PRINCIPE: If they're relevant to CAFI, then okay. CAFI's listed as a potential claim in the bankruptcy. MR. O'BOYLE: I understand. The world doesn't start and stop with CAFI. MR. PRINCIPE: Then ask your questions. MR. O'BOYLE: Could you mark that? (Exhibit 2 marked for identification.) (Recess from 3:53 p.m. 4:01 p.m.) A. You'll have to refresh my question. BY MR. O'BOYLE: Q. Sure. Did you prepare this to the best of your knowledge? A. I don't know. There are a number of pages that are cut off, so I can't say with certainty. Q. Show me which pages are cut off. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 75 A. Well, they're not numbered, so it'll be difficult to -Q. Oh, I don't think so. A. This page is cut off. Q. What's it say? What's the first word that's on there? A. It's cut off. "Affy details such as the purchase." Q. Okay. All right. Now, let's just wait one second and go to the prior page. If you remember, this was one long sheet. So when you cut it, you can't cut perfectly obviously, but it's not cut off. It's just repetitive. It's in total on this page and partial on the next page. A. Okay. I see. Q. And every single page that you find you will see that. Every single page as you would say cut off you will see -A. I see. Yeah, as far as authenticating it, I mean, it looks familiar to me. Without comparing it to what I prepared, what I'm certain I prepared, I couldn't say with certainty that it's verbatim what I created, but it certainly looks familiar. Q. Okay. Now, you say in here that Bill Ring denied Chandler's request to give a case to Thomas M. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 76 Osiero. A. Where -MR. PRINCIPE: Hang on again. Objection. Is it relevant to a 2004 exam? MR. O'BOYLE: I think so. A. What date is that? BY MR. O'BOYLE: Q. Joel, it's -- it looks like June 10th. MR. PRINCIPE: Of what year? MR. O'BOYLE: 2014. This, Frank, is just his tenure at CAFI. A. Okay. The June 4 actually would have been I think on a timeline June 2nd because if this is what I created -- and, again, I'm not authenticating it, so yeah, e-mail to Chandler June 2, 2014, 4:52 p.m. Is that the one you're talking about? Q. Bear with me. No, I was speaking about the next one, but we could talk about that one, the June 4th. That's fine. A. Okay. What would you like to talk about? Q. Okay. Do you have a copy of that e-mail? A. I believe that I do, and I've provided it to CAFI, to Dan back last year with the first request for production, and then it's also on the hard drive that I provided today. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 77 MR. O'BOYLE: Dan, can you give Mr. Chandler the hard drive and can you pull it up for us, that one document? MR. DESOUZA: I think he has it right now. MR. O'BOYLE: Oh, he has it, okay. A. There are many records on there. I don't know how long it might take me to find it. BY MR. O'BOYLE: Q. You can do a search and we can go on. A. Okay. Sure. Q. After you start your search, Joel, we'll continue. A. Okay. I have it. Q. You do have it? A. Uh-huh. Q. Okay. A. Just for future reference, make it easier for you guys, it's in the folder that says "Bob Sweetapple," and it's a PowerPoint file. It was actually created using a different program, but it can be viewed in PowerPoint. Q. So Sweetapple has -- in other words, when you say it's under folder -- under Sweetapple, Sweetapple has a copy, correct? A. I don't know that with certainty. It's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 78 possible that he does. Just because it's in that folder doesn't mean that those are documents that I gave to Sweetapple necessarily. They would have been records that appeared to me to be responsive to whatever document request was made. Q. To whom; by whom? A. CAFI or by you in connection with the 2004 exam. Q. Okay. I have no documents, as you know. A. I'm sorry? Q. I said I have no documents, as you know. A. Well, I provided them to you, but you're disputing that. Q. Okay. Can you read that letter into the record? A. I'm sorry. I thought you wanted me to pull the timeline. Q. Oh, no. No. The letter, Joel, I'm sorry; the one that says June 4th that you were just talking about. A. Oh, the e-mail is what you're talking about. Q. Yeah. Yeah. That's why I said if you do a search, while it's searching we can move on. A. Hold on. Let me find that. That's June 2nd. Yeah, I have it. The date and the time stamp I'm saying is a little bit different, but it's June 2nd. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 79 Q. Okay. A. Yeah. It says from Bill Ring to Joel Chandler, Denise Dimartini, Brenda Russell, and then a CC to William Ring. "Denise and I are speaking to Mr. Tweel of Jackson Kelly again this week; most likely Weds" -presumably Wednesday or Friday -- "however, at this point I'm not inclined to authorize CAFI to engage in another law firm" -THE COURT REPORTER: I'm sorry? Can you please repeat that? THE DEPONENT: I'm sorry. Yeah. I forgot you were doing that. THE COURT REPORTER: "However, at this point I'm not inclined to" -THE DEPONENT: -- "authorize CAFI" -- that's C-A-F-I -- "to engage another law firm based upon my last conversation with Tweel," which is T-W-E-E-L. "We will get back with the definitive answer after that conversation." BY MR. O'BOYLE: Q. And that's it? A. That's all that's in that particular -Q. Letter? A. In that particular e-mail, yeah. Q. Okay. How did that sit with you? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 80 A. I thought it was problematic for a number of reasons. One was the -- this was a concern that you and I discussed very early on, that I thought it was important for CAFI to use more than one law firm other than just your son's law firm for a number of reasons, not the least of which is to avoid the appearance of any impropriety with respect to self-dealing because of your financial interest in both the foundation and the firm. I thought that it would -- my suggestion that you and I discussed and conversations that I had with the board about this was that it didn't necessarily need to be a large number of cases, but at least some cases should be given to other law firms besides the O'Boyle Law Firm. So I wasn't enthusiastic about it, and I thought it was imprudent to take that course. Q. And who -- if Ring would have said "go ahead," who would you have given this case -- and I don't know what case it is? A. Yeah. The particular case you're talking about was actually quite an interesting case. It's a shame it didn't get litigated. Barnes and Nobles college book sellers who actually have been sued over the exact same set of facts in a case that went to the Fourth DCA; I mean, identical facts. And Thomas & LoCicero had expressed an interest in the case, and they found out 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 81 about the case because the time I actually went out to USF and visited Barnes and -- they operate the book store on campus. And they stand in the shoes of the university, and what I asked for were copies of the adoption forms. And these are forms that are circulated by the bookstore to the university faculty for books that they need for upcoming coursework. And these are forms that are requested by off-campus book sellers who are competitors of Barnes and Nobles. And Barnes and Nobles was sued back in I want to say '88 or '89 -- I think a Fourth DCA -- because they refused to give them up claiming that they were proprietary, and the court said that they weren't proprietary, that they collected those on behalf of the university. Well, I went there and made the same public records request to USF. They told me the same thing, and my brother happened to -- we met for lunch, and he happened to follow me on the campus in his vehicle, and we -- he was there, and he made a similar public record request; not the same request, but a similar request the same -- about the same time on the same visit. And he had had a conversation with one of the attorneys at Thomas & LoCicero that he was friendly with, and they had expressed an interest in it. And I thought that given 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 82 the fact that Greg Thomas, who's a senior partner at Thomas & LoCicero, is so highly regarded on both sides of the public records issues, even people who are adversarial towards open government -- that him -- that Thomas & LoCicero being willing to represent the foundation would have added to the foundation's credibility; besides the fact that a large number of the most important appellate cases on open government issues have been argued by Greg or one of his partners. Q. How about -- what would you say if I told you that Bob Tweel -- a senior member of the largest law firm in West Virginia that's 200 years old -- said for the first year you don't need to go outside of where you are, would you say that I'm lying to you? A. No. I couldn't possibly know. Q. Okay. A. If he told you that in the conversation, then I guess -- you know, I wasn't there. Q. So then you don't know what Tweel said, question mark? A. Yeah. The only time that I remember having a -- being involved in any way in a conversation, ever hearing any words come out of somebody's mouth named Bob Tweel was in your office on a conference call very, very, very early in the beginnings of CAFI, when there were 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 83 discussions about just sort of the -- you know, how does all this work, as far as having a 501 C3. So I don't recall other than that having any conversations with Bob Tweel, so I don't know what he said or he didn't say. Q. Okay. A. My -- my argument for engaging another law firm on at least some case -- and not just one other law firm; several other law firms on, you know, a case here, a case there, would have been I think what -- I think what I proposed to Bill Ring and then Denise Demartini, the two board members that I -THE COURT REPORTER: I'm sorry? THE DEPONENT: I'm sorry. THE COURT REPORTER: You said there would have been I think what -THE DEPONENT: Bill Ring -- R-I-N-G -- and then Denise Demartini -- I don't know -- the only two board members that I ever met with together; I think what I was proposing was maybe two or three or four or maybe five cases a month -- probably not that many -- be given to other law firms. And it wasn't -- I wasn't making an argument that there was any legal requirement that the foundation do that. I was arguing that it was a -- politically would have been prudent to do, for the sake of appearance. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 84 BY MR. O'BOYLE: Q. Right. A. And -- and if -- if someone like John Kaney or Andrew Moganen or Greg Thomas or Ed Mullins or some of these other well-known, highly regarded open government litigators were willing to represent the foundation, it would add to the foundation's credibility. Q. I see. Okay. At the time, June 4th, 2014, you would have liked to have used Thomas & LoCicero, if I'm saying it -A. Thomas & LoCicero. Q. Right? A. Yeah -- what day did you just give me? Q. Well, I said as of June 4th you wanted to use them? MR. PRINCIPE: And you were still under the employment of CAFI, correct? THE DEPONENT: Yeah. Yeah. A. In that -- in that -- in that time frame, you know, there's an -- there's an e-mail exchange on June 2nd. I'd have to -- again, without taking more time -- well, yeah, earlier in that day there was -earlier that day there was another e-mail exchange with Bill. This is I think the -- yeah, this is where I actually raised this issue with him, and I wrote going 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 85 back to a phone conference that Marty and I had with Bob Tweel, "the issue of using the law firm other than the O'Boyle Law Firm has come up. The rationale is that if we use the O'Boyle Law Firm exclusively it will appear to be self-dealing by the IRS. Although we have not been -we have not been any concrete suggestions -- obviously that's a typo -- as to how many cases should be referred elsewhere, the consensus has been that we should refer at least some elsewhere. "With that in mind, I would like the board to authorize me to engage Thomas & LoCicero, TLO, T-L-O, to take one case, CAFI versus Barnes and Nobles. My brother Robert was with me when I visited the USF campus bookstore. The bookstore is operated by Barnes and Nobles. Robert mentioned the facts of the case to one of the attorneys at TLo, and they have expressed an interest in the case. I have not yet discussed it -- I have not yet discussed it with TLo. TLo is the preemptive open government law firm in the state. Greg Thomas, the firm's senior partner, has argued many of the landmark public records cases, many of which are regularly cited in briefs, written by the O'Boyle Law Firm." MR. PRINCIPE: Slow down. THE DEPONENT: Sorry. MR. PRINCIPE: She's trying to transcribe. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 86 THE DEPONENT: Just kick me or something if I keep going too fast. THE COURT REPORTER: "Many of the landmark public records cases" -THE DEPONENT: Yeah. "Many of which are regularly cited and briefs written by the O'Boyle Law Firm. I would ask them to take the case on the same terms as the O'Boyle Law Firm contingency, with the firm bearing all litigation costs. I suspect that TLo is interested in the Barnes and Nobles case because it is in Tampa and because Barnes and Nobles was sued over virtually identical facts in a case that made its way to the Third DCF" -- I said Fourth earlier; it's the Third DCA -- "a number of years ago. I think an appellate decision is what TLo is most interested in. Let me know if there are any questions or concerns. I think we need to refer something to someone other than the O'Boyle Law Firm, and this would be a good case to use for that and TLo would always be my first choice. It will enhance the standing of the foundation." BY MR. O'BOYLE: Q. Do you know what kind of lawyer Bob Tweel is? A. A tax attorney, as I understand it. Q. That's correct. And you just read that you 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 87 were -- you, Joel, were worried about the IRS. A. Among other things. I also say in the e-mail to Bill that I believe it would enhance the standing of the foundation. Q. Okay. But what you're saying is Bob Tweel doesn't know what he's doing? MR. PRINCIPE: No that's not what he said. Object to question. Ask him a question. MR. O'BOYLE: Okay. BY MR. O'BOYLE: Q. Bob Tweel, you agree, is a tax lawyer? A. Yes. As far as -- that's what I've been told. I don't know that. Q. Okay. Well, we can go on the Web and look, if you need. A. Right, because everything is accurate. Q. And you were worried about the IRS? A. That was one consideration. Q. I understand, but you were worried about it; you just read it. Let's read it again. Well, just that one sentence. A. Yeah. "The rationale is that if we use the O'Boyle Law Firm exclusively it will appear to be self-dealing by the IRS." Q. Okay. So where did that come from? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 88 A. That was my understanding from the conference call that we had with Bob when I was in your office. For example, you saying a few minutes ago when you stated on the record that Bob said it was okay for the first year. I don't remember whether that's -- that's not my -- I'm not saying it's not what he said. That's not my recollection -- and this is going back a long time ago of the conversation, but that there was the possibility of the appearance of self-dealing. And as I expressed to you and as I expressed to the board both verbally and in writing when I gave them a written warning that I was contemplating leaving, that being involved in Civil Rights activism as I have been for a fair number of years, it has been my experience that if you give the establishment an opening to come after you they will take it. Even when it's trumped up, nonsensical poppycock they will take it and that trying to stay as far away from anything that looks unsavory or questionable is best. Q. Okay. Next time you speak to your lawyers ask them this question, if you don't mind, and that is if you get an opinion from a tax lawyer is there any liability that follows if you do something wrong and the lawyer has opined? A. Yeah, but as I was just saying, my concern was 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 89 not principally a technical violation of the law. That's -- that's not what I'm expressing in the e-mail; that's not certainly what I -- not what I intended to express in the e-mail that I sent to Bill. It's an appearance issue. It was trying to -- I mean, you were going around with the foundation; filed a lot of lawsuits against the establishment, as you yourself have filed a lot of lawsuits against the establishment, as I have. And they get fired up. I mean, your RICO case is a good example. It doesn't matter whether the facts are good or bad or nonsensical. They have very deep pockets, deeper than anybody in this room. Q. Who's "they"? A. The establishment. Q. I see, okay. A. They don't have to have good facts, because it doesn't cost them a penny if they're wrong. It's the taxpayers that pay. They have virtually unlimited resources, even a little town like Gulfstream, for example. It doesn't matter whether a RICO prosecution makes sense or doesn't make sense. They can still spend a bunch of money doing it. They can still harass people by filing -- trying to prosecute people civilly or criminally. And so my point was that to try to stay as far away from anything that would either invite that or 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 90 that would give the establishment cover for doing it. Q. Okay. We sued the Atlantic City press? MR. PRINCIPE: Who's "we"? MR. O'BOYLE: Me and I think Bill Ring represented me, but I'm not sure. It may have been -A. Okay. BY MR. O'BOYLE: Q. And guess who was representing the Atlantic City press? Thomas & LoCicero. A. Okay. Q. Would you want us to hire a law firm that we are adversary -- in an adversarial relationship with? A. I'm not sure I understand the question. Q. Okay. A. I'm sorry. It's getting late in the afternoon. Just kind of break it down for me a little more. Q. Sure. Thomas & LoCicero -A. LoCicero. Q. -- represented our adversary? A. We're talking about Thomas & LoCicero? Q. LoCicero, yeah. A. Okay. Q. I'm not saying it right. A. TLo is what they go by. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 91 Q. Okay. TLo was representing Atlantic City press? A. Okay. Q. How could we -- or CAFI as the case may be -have hired them -- that firm -- when they were adverse? How could that have happened? A. Who were they adverse to? Q. They were adverse to me, but it's -- we're all in the same world. MR. PRINCIPE: Do you have a date? Do you have dates? MR. O'BOYLE: Before -MR. PRINCIPE: That way he's clear what was the law firm. MR. O'BOYLE: It was during the June 4th, 2014. MR. PRINCIPE: Okay. BY MR. O'BOYLE: Q. So that's why Bill Ring wouldn't go along with the program and -MR. PRINCIPE: Is that a question? MR. O'BOYLE: Pardon? MR. PRINCIPE: Please ask a question. MR. O'BOYLE: Yeah. I'm going to do it. MR. PRINCIPE: Okay. BY MR. O'BOYLE: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 92 Q. And that's why -- and he did not want or feel it was appropriate for him to share that with you. And do you understand that? A. No. Q. Okay. You think he should have shared with you? A. Well, let me just mention parenthetically. Putting a question mark on the end of a sentence or a paragraph doesn't make it a question. It's just a statement that you end with an upward inflection in your voice. Q. That's what you say. MR. PRINCIPE: Can you narrow the question? A. I'm sure that there are a number of English teachers that would agree. That was not the discussion that I had with Bill. The e-mail is part of the discussion. We also had in-person discussions both with Bill -- I did with Bill and Denise. My -- the issue for me was not just Thomas & LoCicero. As I've said, Thomas & LoCicero would have always been my first choice. I'm not sure I'm understanding the conflict, though. BY MR. O'BOYLE: Q. Okay. That's fine. A. Help me -- help me -- I'm not trying to be 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 93 obtuse. Help me understand the conflict you're talking about. Q. Let's just juvie it. I think we got enough on that. Now, you contacted Sweetapple before he contacted you, correct? A. Yeah. He never -- to the best of my recollection, Bob Sweetapple never made any effort to reach out to me. I reached out to him. Q. And when you contacted him, it was to destroy the people in my office, including me? MR. PRINCIPE: Objection; it's not relevant to the bankruptcy. MR. O'BOYLE: It's quite relevant. BY MR. O'BOYLE: Q. And you may answer. A. No. Q. "No" what? A. No. No is the answer to your question. Q. Okay. So you did not want to destroy anyone in my office? A. No. Q. Including me? A. No. Q. I see. Then why did you do what you did? You went to as many newspapers as you can go to; am I correct 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 94 there? A. Gosh, I don't know how many newspapers in the world, I don't know. I didn't go to every newspaper that I could have gone to, I don't think. In fact, I don't recall actually going to any newspapers. Q. Okay. A. You mean did I contact some newspapers, people in the media? Q. Yeah, same -- same -- same -- same, yeah. A. Yeah, I did. Yes, I contacted a number of reporters, newspaper editors that I know, yeah, and then I distributed a press release. Q. What was the purpose? A. To make clear that I was no longer affiliated with Citizens Awareness Foundation. Q. And the newspaper articles -MR. PRINCIPE: Can you give me some dates; narrow the dates down? MR. O'BOYLE: Joel is very familiar with them, but I would say, if I had to, between June of '14 or July of '14 and July of '15. That's what I would say. MR. PRINCIPE: Are you asking the question on behalf of CAFI or are you asking the question on behalf of you individually because you say "we"? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 95 MR. O'BOYLE: Okay. I'm sorry, I have a habit of saying "we." I'm asking the question. MR. PRINCIPE: Well, I'm asking if you can clarify it, unless you can answer it. A. You're asking me why I sent that out. I sent it out because you threatened me. BY MR. O'BOYLE: Q. Uh-huh. A. I actually had -- when I made the decision to resign, which I provided a written warning to the board about that. As well as verbally warning them about it, I prepared a pretty moderately-tone press release saying that I had separated from Citizens Awareness Foundation for unresolved, irreconcilable, ethical, and philosophical differences; I think something to that effect. That was all I had intended to do. And then the afternoon or the day that I resigned, which I think was June 30th, you called me, Denise Demartini was on the phone, Bill Ring was on the phone, and you told me -- you said repeatedly that you were going to bring great unpleasantness to my life, presumably this -- what we're doing right now -- was part of that if I did not retract or resend an e-mail exchange that I had had with Nick Taylor. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 96 And just so you remember, Nick Taylor is the attorney that in my presence and in the presence of someone else in your office you said "Nick Taylor, he's a nigger." That's the one I'm talking about. Q. I said that? A. You said that, sir. You most certainly did. You most certainly did. Q. Okay. A. That attorney. You wanted me to withdraw an e-mail exchange that I had with Nick Taylor. Q. Why? A. And I refused to do it, and you repeatedly said that if I didn't withdraw or retract that e-mail exchange with Nick Taylor that you were going to bring great unpleasantness. Q. Why would I want to threaten you to withdraw an e-mail against someone that I referred to as a nigger? A. Marty, I can't begin -Q. Does it make sense to you? A. Much of what you do doesn't make sense, including what we're doing here today makes no sense. Q. Okay. That's fine. A. Why you would want to depose me; why you would want me to talk on the record about my relationship with you or Citizens Awareness Foundation or your son, I don't 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 97 know why you would want that. I'm happy to accommodate, but -MR. PRINCIPE: Well, you have to. You're under -THE DEPONENT: Yeah. Absolutely. I'm happy to accommodate. MR. O'BOYLE: I'm going to ask you to mark these one at a time. There's probably 25 to 30 of them there. (Composite Exhibit 6 marked for identification.) BY MR. O'BOYLE: Q. I'm asking the court reporter now to mark all of the newspaper articles, which for lack of a better way of saying it, trashed my son and trashed me and emanated from you. A. Seriously, Marty, if you're going to testify you got to be under oath. Q. Okay. A. I mean, you're testifying. You're doing it repeatedly. Can we put him under oath? Do you want to say that again under oath? Q. You're welcome to depose me anytime you want. A. By the way, the deposition works is you ask the questions. You don't get to make statements, and you're 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 98 just making statements. Q. Okay. A. And I'm objecting to you making statements. Ask questions. Q. You've made it clear. From now on when I make a statement, if you would just do this, Mr. Chandler, I'll know exactly what you mean. We'll save a bunch of time. A. Well, we'd save even more time if you quit making statements and ask questions. Q. Okay. MR. PRINCIPE: Can I see the -MR. O'BOYLE: Yes, you may, Frank. MR. PRINCIPE: May I -BY MR. O'BOYLE: Q. Anyway, those newspaper articles, they emanated from you, didn't they? MR. PRINCIPE: Look at them first. A. Well, I'm not a newspaper reporter, so they couldn't have. MR. PRINCIPE: I think you ought to look at them to make sure you're testifying correctly. BY MR. O'BOYLE: Q. Did you ever have any newspaper articles about me or my son on your website? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 99 A. I -- from time to time I have linked various articles relating to open government issues on my website, yes. And off the top of my head I couldn't tell you which ones, because there are a lot. Q. If I -- if I told you that you had six articles on your website, which I would use the term "trashed" me and my son, would you say that I'm lying? MR. PRINCIPE: Give me your definition of "trash." MR. O'BOYLE: Trash; saying you're a bad guy; saying that you're a crook; saying not nice things, Frank. MR. PRINCIPE: You can answer that question. A. I don't remember using the word "crook." I don't remember using the "trash." I don't remember -- I don't remember -- you're asking me under oath to say did I say something, and you're using words that I don't think I used. BY MR. O'BOYLE: Q. Okay. That's fine. Did you at any time have six articles wherein my son's name and your -- and my name were mentioned and they were on your website? A. I don't know. Q. Okay. Five? A. I don't know. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 100 Q. Four. A. I don't know. Q. Three? A. I don't know. MR. PRINCIPE: Do you have the six articles that maybe he could look at them and then he could answer them? MR. O'BOYLE: He pulled them off of his website I guess in anticipation of this deposition. MR. PRINCIPE: I object to that. I mean, you're speculating. A. I don't think I've taken anything down off the website. BY MR. O'BOYLE: Q. They're down off the website. MR. PRINCIPE: Answer the question. BY MR. O'BOYLE: Q. They're down off the website; and, of course -have you made changes to the website recently? A. Define "recently." Q. Last six months. A. I couldn't say with certainty. It's been I think many months since I've done anything on it. Q. Okay. Do you know Ryan Witmer? A. I do. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 101 Q. How do you know him? A. I first met him at your office at Commerce Group. I can't remember when it was. I seems like it was maybe 2013; delightful guy, very sweet. Q. But yet you knowingly or unknowingly in connection with your relationship with the town of Gulfstream, you have prevented Ryan Witmer from becoming a member of the Bar -MR. PRINCIPE: Objection to the question. BY MR. O'BOYLE: Q. Were you aware that, please, Mr. -A. No. I'm not aware of any of that. Q. You're not aware of any of that? A. (Witness shaking head.) Q. Were you aware there was a RICO suit filed? A. I imagine that a lot of RICO suits get filed. Q. Well, you imagine there was a RICO suit -- did you know there was a RICO suit filed by the Town of Gulfstream against myself and 14 others? A. I wasn't aware of all of the defendants. I know that there was a -- I believe there was a RICO case. I think it was dismissed by the federal court, but imprudently in my opinion I understand it's being appealed. Q. And when you say "imprudently" in your opinion, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 102 did you offer that opinion to anyone? A. I've offered that opinion to a whole bunch of people. Q. Uh-huh. Now, Ryan Witmer, he used to do -what do you call -- record cases. Are you aware of that? A. You mean public records lawsuits? Q. Yeah. I'm sorry. Yes. A. Yeah. Q. Okay. And Ryan, if he were here, he would say that he had a good relationship with you, that you supplied him the templates and -MR. PRINCIPE: Objection to the line of questioning. There's no question you're making statements. MR. O'BOYLE: No. I'm making a question. MR. PRINCIPE: No. Ask him a specific question. Don't answer it, until he's asked you a question. MR. O'BOYLE: Okay. Can you read back? THE COURT REPORTER: The last question? MR. O'BOYLE: Yeah, last question, please. And when you get to the point where Mr. Principe rudely interrupts, just stop and I'll finish it. (The preceding question was read by the court reporter.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 103 MR. PRINCIPE: No. It's the next one down; the next question. (The preceding question was read by the court reporter.) MR. O'BOYLE: Okay. MR. PRINCIPE: There's another question. (The preceding question was read by the court reporter.) MR. PRINCIPE: That's when I objected because it's not a question. MR. O'BOYLE: I wasn't finished; that's why. BY MR. O'BOYLE: Q. That you supplied him templates -- and these are my words -- but a basket of cases I guess for him to go to court, if he had to go to court; is that correct? A. I have no idea what Ryan would say if he were here. Q. Pardon? A. I have no idea what Ryan would say if he were here. Q. Well, let's try it a different way. A. Please. Q. Did you give Ryan the templates that he was using? No? A. What kind of templates? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 104 Q. The templates for the public records suits. A. I provided to Ryan -- as I recall, when I first met Ryan and Bill Ring at your offices, I think at some point after that meeting I provided to Bill and to Ryan documents that I had used for my own pro se litigation, and then when the -- when CAFI was started and the O'Boyle Law Firm was engaged to represent CAFI in some public records lawsuits, I think I did the same thing again, some updated documents that I had used for my own litigation. And so, yeah, I think that would be a fair statement in that context anyway. Q. And in connection with your timeline here, you make a comment, if I can find it, that is a comment from Barbara Chandler. Do you remember that? A. I don't know a Barbara Chandler. Q. Barbara -- I'm sorry, Barbara Peterson. Does that sound right? MR. PRINCIPE: Do you have a page number he can refer to? MR. O'BOYLE: I do; June 12th. MR. PRINCIPE: About halfway in? June 12th. MR. O'BOYLE: And, Frank, don't be such a meanie to me. A. You're talking about Chandler meets with Barbara Peterson June 12, 2014? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 105 THE COURT REPORTER: I'm sorry, can you repeat that? THE DEPONENT: I'm sorry. A. "Chandler meets with Barbara Peterson June 12, 2014. Chandler meets with Barbara Peterson of the Florida First Amendment Foundation and seeks her counsel on his ethical concerns. She echoes Greg Thomas' advice, but adds that to preserve the -- his credibility, Chandler's departure must be very public and that Chandler should tell MEO to go -- quote 'go fuck himself,'" unquote. It's one of the things I love about Barbara. She's so expressive. BY MR. O'BOYLE: Q. Now, is that you talking or is that Barbara Peterson? A. No. Those are the exact words that came out of her mouth. We were sitting at the -- I want to say it's called the Intercontinental now. It's used to be the Lincoln; it's that big hotel on Westshore and Kennedy where the Shula's steakhouse is. We were sitting in the bar. She had a meeting; the board of the directors of the First Amendment Foundation. She was in town and so she happened to be in town. It was close by, and I happened to be doing work over here, so I met with her. And when I described what 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 106 was going on with Citizens Awareness Foundation and the O'Boyle Law Firm and Marty O'Boyle and Jonathan O'Boyle, she had the same response that a number of other attorneys had, which was "why are you still there, you need to leave." She was concerned about making sure that my departure was public; not necessarily explosive. And that's the reason that prior to my resignation when I knew that I was going to resign I prepared the press release and had hoped, as I expressed to you on the telephone when you called me and threatened me, that that would be the end of it; you go your way, I go mine; no hard feelings. It just didn't work out. But when you started saying to me -- and you said it repeatedly -- that if I didn't retract or resend the e-mail, which I don't really understand how you would do that -THE COURT REPORTER: I'm sorry? THE DEPONENT: I'm sorry. (The preceding question was read by the court reporter.) A. The e-mail that I exchanged with Nick Taylor just before my resignation -- I think it was the Thursday prior to my resignation -- on a Monday -- that's what precipitated me contacting not only Bob Sweetapple, but a number of other attorneys who were representing 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 107 defendants who were being sued by CAFI. BY MR. O'BOYLE: Q. Okay. And your counsel has a -- and I don't know that I have another one, but your counsel has the transcript from when you met with Bob Sweetapple. Do you remember that? A. The meeting? You mean do I remember the meeting with Bob Sweetapple? Q. Yeah. A. Yes. I remember the meeting. Q. Okay. Now -- and also you did an affidavit? A. I believe that I did. MR. O'BOYLE: Do we have that marked? THE COURT REPORTER: We have 3, 4; then the newspaper -(Exhibits 3 and 4 marked for identification.) MR. PRINCIPE: Right now I object to that being offered into evidence. I don't think it pertains to a 2004 exam. THE COURT REPORTER: I'll mark it 5. Did you want to -- you said you wanted the newspaper ones marked individually? (Exhibit 5 marked for identification.) MR. O'BOYLE: Yeah. But I don't think we're going to go into them. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 108 BY MR. O'BOYLE: Q. Okay. So when we get back to the timeline you said Barbara Peterson told you to "tell Marty O'Boyle to go fuck himself"? A. Yes. Q. Okay. Now, are you sure about that being true as you are with this sworn statement that you did for Bob Sweetapple on July 23rd and the affidavit that you did on October 27, 2014? Are you sure that Barbara Peterson's statement is -- are you sure that -- that -- that these two documents -MR. PRINCIPE: What are the documents, so we're clear? MR. O'BOYLE: I'm sorry, Frank. This is -- is this Exhibit 5, yeah. BY MR. O'BOYLE: Q. Exhibit 5 and Exhibit 4. Are you sure that they are true and correct as you are that Barbara Peterson's statement is true and correct from the timeline? A. I'd have to read through this again. I mean, if you want me to I will. Q. Well, you want to take it home? MR. PRINCIPE: Yeah. Why not? A. No. I don't want to take it home. I got other 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 109 things to do with my life. MR. PRINCIPE: All right. A. I'm a little -- did Barbara Peterson say to me "tell Marty to go fuck himself," yes, she said that. Was it verbatim that? I believe that it was. Was it "tell him to go fuck himself" or "tell Marty O'Boyle to go fuck himself" or "tell Marty to go fuck himself" -THE COURT REPORTER: I'm sorry. Can you slow down? THE DEPONENT: Yeah. Sorry. A. Was it him; was it Marty O'Boyle; was it Marty; was it O'Boyle. I believe she said your full name, as I recall. BY MR. O'BOYLE: Q. But generally stated it's true? A. Yeah. It's true. Q. Okay. And my question is, you're saying that that's true. Are you -- when I look at the affidavit and I look at the transcript is -- are they as true as Barbara Peterson's statement? You did them under oath. A. I believe that my description of the exchange of Barbara Peterson is accurate. Q. And? A. I believe that if I gave a sworn statement, that it's accurate. Am I fallible? I suppose it's 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 110 possible. I may have used the wrong verb or I don't know. It's possible that there might be a -- what might otherwise be referred to as a scriveners error, but do I believe that -- that what I said is true and accurate, yes. Do I believe that's the same, as far as an affidavit that I put my hand to, yes. Q. Okay. So generally stated what I think I hear you saying -- and you'll answer me yes or no -- is that you can rely on my timeline that makes the statement about Barbara Peterson saying for Marty O'Boyle -- or some derivative of that, Marty, him, whatever -- to go fuck himself, you can rely on that being true the same as you can rely on the affidavit and on the transcript? A. No. I cannot rely on your timeline. As I've said, I cannot authenticate this. Q. I'm not asking the timeline. A. You said is it -- you referred to the timeline just now. Q. I referred to Barbara Peterson. A. From the timeline. Q. Right. A. And what I'm saying is I cannot confirm the veracity of what you have presented as an exhibit because I have not authenticated it against the original that I know that I created. It looks familiar to me. I'm not 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 111 saying it's not the same thing. I'm saying that I can't authenticate it. Q. I understand. Did Barbara Peterson say "tell Marty O'Boyle to go fuck himself"? A. Yes. Q. Okay. And are you sure about that as you are that the content of the transcript and the affidavit are true and correct? A. Well, it's the -- your -- the "as sure" language is troubling and I feel it is somewhat unclear. You've asked me under oath if my recollection is that Barbara Peterson uttered those words, and I said yes, something to that effect. Q. Right. You sure did. A. You've asked me if when I put my hand in an affidavit, assuming this is a true copy -- I don't know if it is -- if I put my hand on an affidavit that I believe that it was true, yes. If I put myself under -if I was under oath for a sworn statement, I believe that my utterances were true. So the whole "as thing" I don't know it's true, it's true, it's true. What Barbara said, yes, she said that. Q. Okay. I think that's fine. Let me ask you a few questions about this affidavit. "Simply put, CAFI is a profit-generating scheme funded by Martin O'Boyle, 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 112 produced to use for his son's legal practice." Where's that come from? A. I think the facts, sadly. Q. "Profit-generating scheme." Where did that come from? A. All right. Again, I think we really need to object to the line of questioning because I feel like we've been accommodating. I've answered a lot of questions today and very, very, very few, if any, have anything to do with my finances or the truthfulness of my statement to the court. As far as the bankruptcy's concerned, I'm happy to answer questions about -- let me finish -- in response to your question. I'm happy to answer questions, be accommodating, provide documents relating to my bankruptcy, relating to all my finances, but we're talking about things that are so -- the only way that there's even a remote connection is the fact that CAFI is suing me, but they're a creditor. That lawsuit has been stayed and the 2004 examination is not intended to be used to gain an unfair advantage in an adversarial proceeding outside of the bankruptcy. It's intended to be used by creditors to try to discover hidden assets. I'm an open book. I don't have any assets to hide. Q. You may answer. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 113 A. I'm answering your question. MR. PRINCIPE: And we're objecting. We're objecting. A. And I'm objecting to that. BY MR. O'BOYLE: Q. Okay. MR. PRINCIPE: Do you want to answer it or not? THE DEPONENT: No. Frank, look, I feel like we're done here. MR. O'BOYLE: When you say, Frank, that -- this is a question directly on CAFI and you're instructing him not to answer? MR. PRINCIPE: I think he can answer that, if it's directly on CAFI. BY MR. O'BOYLE: Q. Paragraph 66. "Simply put, CAFI is a profit-generating scheme." A. CAFI was -Q. Let's just answer. Let's keep it short. Let's not make speeches. A. Ask your question again. Q. Paragraph 66 says "Simply put, CAFI is a profit-generating scheme." MR. PRINCIPE: Where's that at? MR. O'BOYLE: In the affidavit, Frank. I may 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 114 even have another one, but I don't know. A. Okay. BY MR. O'BOYLE: Q. Okay. "Funded by Martin O'Boyle to produce fees for his son's legal practice." A. Yes. Q. Okay. A. I stand by that. Q. Okay. And give me the factual basis. A. The factual basis is laid out in my motion to dismiss. It's laid out in the sworn statement. Q. Let's -- I'm asking you. I'm not -A. Can I finish my -Q. Sure. A. If you ask me a question, you're going to have to let me finish them. Q. Sure. Go ahead. A. I think the ultimate facts of CAFI and the O'Boyle Law Firm are sadly that Citizens Awareness Foundation was not created to be an advocacy organization for the rights of citizens in Florida to have greater access to public records and open meetings. I think that ultimately the chief ambition was to generate lawsuits, all of which were channelled to your son's law firm, which you financed. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 115 You financed both your son's law firm and your long-time employee, Denise Demartini, had managerial control of that law firm, in spite of the fact that she was not a licensed attorney in Florida. You also funded Citizens Awareness Foundation. Your proxy, Denise Demartini, in writing demanded that I produce at least 25 lawsuits per week. She demanded that I draft lawsuits. It was clear that the ambition all that mattered was let's see how many lawsuits we can file, and then on top of filing lawsuit after lawsuit after lawsuit -- and the lawsuits that I referred to the foundation, the facts were good, no question in my mind that they were real violations of Public Records Act, but one of the ultimate concerns and I think validations of my statement that it was nothing more than a revenue-generating scheme is the fact that the law firm kept demanding settlement amounts that were far beyond the actual fees that they earned. And that was the e-mail exchange that I had with Nick Taylor where I challenged him on that issue. I had challenged the board on this repeatedly; and in fact immediately after my meeting with Barbara Peterson while I was still in the hotel parking garage, I got a phone call. And it was Denise, John -- Denise Demartini, Bill Ring, and Jonathan O'Boyle were on the 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 116 phone and I was still on the phone with them, on the same telephone call by the time I got back -- all the way back to Lakeland. And I was as blunt, direct, undiplomatic, crass, vulgar as I could be in explaining to them my absolute objection to the law firm making demands for payment beyond the actual fees and costs that they had earned and accrued. Q. And you're talking about -A. Let me finish my questions. Q. Your question. A. I answered your question. Q. Okay. A. I was as vociferous and blunt as I could be in explaining that position that I was adamantly opposed to it, that I wouldn't agree to it, that I wouldn't be associated with the organizations if this continued. And yet I got a phone call the following day, two phone calls -- one from one person at the law firm and another from another person at the law firm telling me that Denise, Jonathan, and Bill had gone in the very next day and that Joel approved of the program, because the other attorneys knew that I didn't, because I had been apoplectic with them about my objections to it. And I think that the fact that no lawsuits could be filed with any other law firm, that there was a 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 117 quota that was imposed upon me to produce 25 lawsuits per week -- which is I think is beyond disputed because there's an e-mail exchange that I have with Denise where she says that -- and the fact that the law firm was repeatedly demanding fees and costs far beyond what had actually been accrued I think evidenced my statement that it was nothing more than a review-generating scheme. And I'm all for people making money and I'm all for the attorneys getting paid. Q. I think you're far beyond the question, but I appreciate that answer. A. So I can't say any more. You cut me off. Q. No, I think it's time. I think you've answered long enough. A. You asked me an open-ended question. I tried to answer it. Q. I understand. I appreciate it. MR. DESOUZA: What was the question? I heard the answer, but I didn't hear the question. MR. O'BOYLE: We're not going there. I'll play it for you tonight. THE DEPONENT: He was asking me from page 10 of the affidavit, number 66. "Simply put, CAFI is a profit-generating scheme funded by Martin O'Boyle to produce fees for his son's legal practice." He 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 118 asked me what facts there were to support that. A. There are a lot of other facts, but you cut me off. BY MR. O'BOYLE: Q. Okay. Good. A. So I guess we're done with questions, since you're cutting me off and not letting me answer them in full. You asked me what facts there are. There are more, which I'll be more than happy to continue to put on the record, but you're not going to let me. Q. Go ahead. Put them on the record. Make yourself happy. A. What time are we stopping? Q. 6:00. MR. PRINCIPE: No, we said 5:00. MR. O'BOYLE: We didn't anticipate a filibuster. THE DEPONENT: Marty, you're the one who's filibustered. You've gone and made statements. You asked me questions. You cut me off. Don't accuse me of filibustering. You asked me a question; I answered. You're the one who made statements without being under oath. MR. O'BOYLE: You can answer that question then tomorrow. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 119 MR. PRINCIPE: We're going to take hers tomorrow morning? MR. DESOUZA: Marty, let me finish. MR. O'BOYLE: Go ahead. THE DEPONENT: No. I'm done. You cut me off. I'm done. I'm done. MR. PRINCIPE: You can ask that question again tomorrow, if you want. THE DEPONENT: Ask it again tomorrow. I'll be more than happy to say it again tomorrow. MR. O'BOYLE: Well, I'm going to ask questions, and if you want to answer your question we said you can. So continue on. THE DEPONENT: You cut me off. Do you want to ask again tomorrow? Look, it's 5:00. MR. O'BOYLE: I apologize. I apologize. THE DEPONENT: Marty, it's 5:00. You want to ask it again tomorrow, ask it again tomorrow. MR. DESOUZA: All right. Everyone time-out for a second. Can we go off the record? (Discussion off the record and deposition concluded.) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 120 CERTIFICATE OF OATH STATE OF FLORIDA ) COUNTY OF HILLSBOROUGH ) I, the undersigned authority, certify that JOEL EDWARD CHANDLER personally appeared before me and was duly sworn. WITNESS my hand and official seal this 1st day of October, 2015. _______________________________ VANESSA MENDOZA, FPR Notary Public State of Florida at Large My Commission Number: FF078246 Expires: 12/19/2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 121 CERTIFICATE OF REPORTER STATE OF FLORIDA ) COUNTY OF HILLSBOROUGH ) I, VANESSA MENDOZA, certify that I was authorized to and did stenographically report the foregoing deposition and that the transcript is a true record of the testimony given by the witness. I FURTHER CERTIFY that I am not a relative, employee, attorney, or counsel of any of the parties, nor am I a relative or employee of the parties' attorneys or counsel connected with the action, nor am I financially interested in the action. DATED this 22nd day of January 2016. ____________________________________ VANESSA MENDOZA, FPR Notary Public State of Florida at Large My Commission Number: FF078246 Expires: 12/19/2017 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 122 SIGNATURE PAGE/ERRATA SHEET WITNESS: JOEL EDWARD CHANDLER INSTRUCTIONS TO WITNESS After you have read the transcript of your deposition, please note any errors in the transcription on this page. Do not mark on the transcript itself. Please sign and date this page as indicated below. If additional lines are required for corrections, attach additional pages. PAGE/LINE ERROR OR AMENDMENT/REASON FOR CHANGE _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ ______________________________ _________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ ______________________________ _________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ _______________________________________________________ ______________________________ _________________________ ____ ____ _____________________________________________ I have read the transcript of my deposition and subscribe to its accuracy, to include the corrections or amendments noted above or attached hereto. ___________________________________ Signature of witness Date ' '14[2] - 94:20, 94:21 '15[1] - 94:21 '88[1] - 81:11 '89[1] - 81:11 'go[1] - 105:10 1 1[6] - 1:11, 4:3, 56:12, 72:4, 72:5, 72:6 1.1[1] - 51:7 1.3[1] - 51:7 10[3] - 9:3, 9:7, 117:22 100[1] - 2:7 101[1] - 2:10 107[3] - 4:5, 4:6, 4:7 10th[1] - 76:8 12[2] - 104:25, 105:4 12/17/14[1] - 38:12 12/19/2017[2] 120:15, 121:24 120[1] - 3:7 121[1] - 3:8 122[1] - 3:9 1280[1] - 2:3 12th[2] - 104:20, 104:21 13[3] - 30:17, 30:18, 30:21 1355[1] - 5:19 14[1] - 101:19 15[1] - 60:2 1500[1] - 2:10 1990[1] - 40:11 1:47[1] - 1:12 1st[1] - 120:7 2 2[4] - 4:4, 51:6, 74:17, 76:15 20[1] - 6:17 200[1] - 82:12 2004[20] - 5:12, 10:15, 11:21, 14:9, 16:21, 22:22, 22:25, 23:2, 23:5, 29:13, 29:16, 45:16, 48:17, 49:15, 74:6, 74:7, 76:4, 78:7, 107:19, 112:20 2013[1] - 101:4 2014[10] - 66:22, 67:12, 67:16, 76:10, 76:15, 84:8, 91:15, 104:25, 105:5, 108:9 2015[2] - 1:11, 120:8 2016[1] - 121:18 21[1] - 43:8 22nd[1] - 121:18 23rd[1] - 108:8 24[1] - 36:13 25[4] - 36:8, 97:8, 115:6, 117:1 27[2] - 67:12, 108:9 2805[1] - 2:7 2:03[1] - 15:6 2:08[1] - 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6:3, 20:23, 20:25, 21:1, 28:12, 30:4, 32:1, 32:14, 32:15, 34:10, 34:18, 40:2, 43:3, 43:5, 44:3, 47:10, 48:6, 64:8, 64:22, 112:8, 116:11, 117:13, 118:22 answering[3] - 29:12, 45:9, 113:1 answers[4] - 18:23, 31:25, 35:11, 65:23 anticipate[1] - 118:16 anticipated[1] - 71:19 anticipation[1] 100:9 anytime[1] - 97:23 anyway[2] - 98:16, 104:11 apartment[1] - 25:10 apologize[2] - 119:16 apoplectic[1] 116:23 appealed[1] - 101:24 appear[2] - 85:4, 87:23 appearance[4] - 80:6, 83:25, 88:9, 89:5 APPEARANCES[1] 2:1 appeared[2] - 78:4, 120:5 Appearing[1] - 2:2 appellate[2] - 82:8, 86:15 appended[1] - 52:4 Apple[2] - 52:6, 55:22 appreciate[2] 117:11, 117:17 appropriate[1] - 92:2 approved[1] - 116:21 arbiter[1] - 13:3 argue[3] - 35:5, 57:19 argued[2] - 82:9, 85:20 arguing[1] - 83:24 argument[2] - 83:6, 83:22 arrangements[1] 8:5 arrears[1] - 8:6 arrested[1] - 40:8 articles[8] - 94:16, 97:14, 98:16, 98:24, 99:2, 99:5, 99:21, 100:5 assert[2] - 33:21, 39:4 asserting[1] - 39:9 assertions[1] - 39:5 assets[2] - 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101:8 bar[1] - 105:21 Barbara[21] - 104:14, 104:15, 104:16, 104:25, 105:4, 105:5, 105:12, 105:14, 108:3, 108:9, 108:18, 109:3, 109:20, 109:22, 110:10, 110:19, 111:3, 111:12, 111:21, 115:22 Barnes[8] - 80:21, 81:2, 81:10, 85:12, 85:14, 86:10, 86:11 based[3] - 45:7, 66:24, 79:16 basis[4] - 60:10, 60:13, 114:9, 114:10 basket[1] - 103:14 Beach[3] - 2:4, 43:13, 66:24 bear[2] - 63:19, 76:17 bearing[2] - 70:19, 86:9 became[1] - 67:2 becoming[1] - 101:7 begin[3] - 66:17, 70:17, 96:18 beginning[1] - 7:24 beginnings[1] - 82:25 begs[1] - 35:15 behalf[4] - 42:16, 81:14, 94:24, 94:25 belief[1] - 36:15 below[1] - 122:6 bend[1] - 36:25 best[12] - 11:3, 14:20, 36:14, 37:1, 54:7, 55:13, 64:14, 64:17, 74:21, 88:19, 93:6 better[2] - 68:15, 97:14 between[1] - 94:20 beyond[8] - 11:11, 29:16, 63:10, 115:17, 116:6, 117:2, 117:5, 117:10 big[1] - 105:19 Bill[17] - 75:24, 79:2, 83:10, 83:16, 84:24, 87:3, 89:4, 90:4, 91:18, 92:16, 92:18, 95:20, 104:3, 104:4, 115:25, 116:20 bit[1] - 78:25 blunt[2] - 116:3, 116:13 board[8] - 80:11, 83:11, 83:18, 85:10, 88:11, 95:10, 105:21, 115:21 Bob[20] - 11:9, 11:25, 27:5, 71:9, 71:17, 77:18, 82:11, 82:23, 83:3, 85:1, 86:23, 87:5, 87:11, 88:2, 88:4, 93:7, 106:24, 107:5, 107:8, 108:7 book[5] - 10:13, 80:21, 81:2, 81:9, 112:24 books[1] - 81:7 bookstore[3] - 81:6, 85:14 borrow[2] - 60:17, 60:23 Boulevard[1] - 2:7 Boyle[2] - 2:5, 5:11 Boyle's[1] - 50:14 break[1] - 90:17 Brenda[1] - 79:3 briefs[2] - 85:22, 86:6 bring[5] - 49:16, 50:15, 61:9, 95:21, 96:14 broad[3] - 65:20, 65:22, 66:16 broader[1] - 29:15 brother[2] - 81:18, 85:12 Broward[1] - 43:13 bunch[4] - 11:8, 89:22, 98:7, 102:2 Burns[1] - 1:13 Busch[1] - 2:7 BY[101] - 1:16, 5:10, 6:14, 7:15, 10:18, 12:12, 13:1, 14:16, 15:8, 15:15, 15:23, 17:3, 17:12, 18:21, 20:5, 20:19, 21:5, 24:7, 24:23, 25:4, 25:14, 26:2, 26:20, 27:20, 28:3, 28:10, 29:22, 32:6, 32:13, 32:24, 34:20, 36:6, 36:11, 37:16, 38:6, 124 38:17, 39:21, 41:22, 42:25, 43:6, 43:11, 46:4, 46:17, 47:14, 48:9, 48:15, 49:5, 49:10, 49:14, 50:18, 51:25, 52:23, 53:15, 54:11, 54:20, 56:10, 59:9, 59:20, 60:4, 60:21, 62:25, 63:25, 64:11, 65:12, 65:17, 66:5, 67:17, 69:17, 70:13, 71:4, 72:11, 74:20, 76:7, 77:8, 79:20, 84:1, 86:22, 87:10, 90:8, 91:17, 91:25, 92:23, 93:14, 95:7, 97:12, 98:15, 98:23, 99:19, 100:14, 100:17, 101:10, 103:12, 105:13, 107:2, 108:1, 108:16, 109:14, 113:5, 113:15, 114:3, 118:4 C C3[1] - 83:2 CAFI[58] - 2:9, 11:8, 23:16, 23:18, 27:13, 27:16, 27:19, 33:3, 56:3, 57:2, 62:6, 65:7, 65:9, 65:13, 65:18, 66:4, 66:6, 66:20, 67:18, 67:20, 68:16, 70:1, 70:24, 71:2, 71:6, 71:10, 72:1, 74:8, 74:10, 74:14, 76:11, 76:23, 78:7, 79:7, 79:15, 79:16, 80:4, 82:25, 84:17, 85:12, 91:4, 94:24, 104:6, 104:7, 107:1, 111:24, 112:18, 113:11, 113:14, 113:16, 113:18, 113:22, 114:18, 117:23 CAFI's[2] - 74:5, 74:11 campus[4] - 81:3, 81:9, 81:19, 85:13 cannot[5] - 73:17, 73:20, 110:14, 110:15, 110:22 capable[5] - 41:3, 41:4, 41:10, 41:11, 41:13 car[4] - 16:24, 17:2, 44:8, 44:9 Case[1] - 1:4 case[30] - 5:15, 23:19, 30:24, 54:1, 54:14, 55:18, 56:14, 61:5, 63:10, 75:25, 80:17, 80:18, 80:19, 80:20, 80:23, 80:25, 81:1, 83:7, 83:8, 85:12, 85:15, 85:17, 86:7, 86:10, 86:12, 86:19, 89:9, 91:4, 101:21 cases[9] - 80:12, 82:8, 83:20, 85:7, 85:21, 86:4, 102:5, 103:14 cash[2] - 8:1, 8:7 causes[1] - 36:23 CC[1] - 79:3 Center[1] - 2:3 certain[3] - 67:12, 70:16, 75:21 certainly[9] - 56:25, 62:14, 62:16, 70:19, 74:2, 75:23, 89:3, 96:6, 96:7 certainty[6] - 47:20, 73:17, 74:24, 75:22, 77:25, 100:22 CERTIFICATE[2] 120:1, 121:1 certificate[1] - 49:7 Certificate[2] - 3:7, 3:8 certify[2] - 120:4, 121:4 CERTIFY[1] - 121:8 challenged[2] 115:20, 115:21 Chandler[27] - 5:11, 5:14, 5:19, 5:21, 15:9, 28:19, 32:4, 36:7, 40:8, 48:10, 48:16, 52:1, 59:21, 64:1, 64:2, 73:25, 76:15, 77:1, 79:2, 98:6, 104:14, 104:15, 104:24, 105:4, 105:5, 105:10 CHANDLER[7] - 1:4, 1:5, 1:9, 3:2, 5:6, 120:5, 122:2 Chandler's[3] - 57:7, 75:25, 105:9 change[2] - 48:24, 56:5 CHANGE[1] - 122:8 changed[2] - 8:3, 73:10 changes[1] - 100:19 changing[1] - 48:21 channelled[1] 114:24 Chapter[11] - 1:6, 30:17, 30:18, 30:21, 38:14, 53:24, 54:1, 54:3, 54:12, 54:14, 56:14 chapter[1] - 56:13 character[8] - 36:25, 40:14, 40:20, 40:22, 40:23, 40:24, 40:25, 41:10 characterization[1] 68:23 characterize[1] 44:23 Charles[1] - 41:7 check[1] - 68:7 chief[1] - 114:23 choice[2] - 86:20, 92:21 chronological[1] 71:15 circulated[1] - 81:6 circus[1] - 11:7 cited[2] - 85:21, 86:6 Citizens[14] - 30:22, 31:1, 44:19, 45:5, 60:5, 66:9, 66:21, 67:2, 94:15, 95:13, 96:25, 106:1, 114:19, 115:5 citizens[1] - 114:21 City[4] - 48:3, 90:2, 90:10, 91:1 Civil[1] - 88:13 civilly[1] - 89:23 claim[13] - 11:9, 31:6, 31:7, 31:10, 33:2, 35:25, 37:12, 37:17, 38:5, 41:23, 43:7, 62:6, 74:11 claiming[1] - 81:12 claims[10] - 23:20, 35:12, 35:18, 36:16, 37:22, 43:2, 43:7, 43:12, 43:21, 59:24 Clara[2] - 47:5, 47:7 clarification[1] 35:22 clarify[1] - 95:4 clear[11] - 11:6, 36:22, 42:11, 55:15, 62:12, 63:5, 91:13, 94:14, 98:5, 108:13, 115:8 close[2] - 39:15, 105:24 Cloud[1] - 48:4 collected[1] - 81:14 college[1] - 80:21 coming[5] - 21:22, 22:11, 22:13, 26:22, 40:6 comment[2] - 104:13 Commerce[2] - 2:3, 101:2 Commission[2] 120:14, 121:23 communications[1] 46:11 compare[5] - 69:20, 69:24, 72:23, 73:4, 73:18 comparing[1] - 75:20 compel[1] - 13:5 compensation[1] 67:10 competitors[1] - 81:9 complete[1] - 70:1 Composite[1] - 97:10 composite[1] - 72:7 compound[4] - 15:17, 25:16, 26:25, 28:2 compromise[1] - 68:5 compromised[4] 68:9, 69:18, 69:19, 69:23 computer[8] - 50:2, 52:5, 52:6, 52:7, 53:6, 53:7, 53:11, 58:20 computers[1] - 50:7 concept[2] - 70:8, 70:9 concern[3] - 45:9, 80:2, 88:25 concerned[4] - 34:22, 41:10, 106:5, 112:12 concerning[1] - 36:9 concerns[3] - 86:17, 105:7, 115:14 concluded[1] 119:22 conclusion[1] - 46:7 conclusions[2] 42:14, 42:20 concrete[1] - 85:6 condition[2] - 10:11, 24:12 conference[3] 82:24, 85:1, 88:1 confident[5] - 33:23, 33:25, 34:2, 34:3, 35:8 confirm[1] - 110:22 conflict[2] - 92:22, 93:1 confused[1] - 22:4 connected[1] 121:11 connection[18] 5:12, 18:4, 18:25, 19:1, 49:11, 53:25, 54:13, 56:14, 59:22, 60:5, 61:5, 71:6, 71:16, 78:7, 101:6, 104:12, 112:18 consensus[1] - 85:8 consideration[1] 87:18 consisting[1] - 36:13 consult[4] - 33:22, 34:16, 35:9, 46:9 consulted[1] - 47:22 contact[1] - 94:7 contacted[6] - 8:2, 46:15, 93:4, 93:9, 94:10 contacting[1] 106:24 contemplating[1] 88:12 content[1] - 111:7 context[5] - 51:14, 65:14, 70:19, 71:14, 104:11 contingency[1] - 86:8 continue[3] - 77:12, 118:9, 119:13 continued[1] - 116:16 contract[1] - 68:4 control[2] - 70:1, 115:3 conversation[9] 42:6, 71:9, 71:19, 79:17, 79:19, 81:23, 82:17, 82:22, 88:8 conversations[10] 14:8, 21:12, 21:15, 21:16, 21:19, 21:21, 71:21, 71:23, 80:10, 83:3 copies[3] - 52:7, 53:19, 81:5 copy[3] - 76:21, 77:24, 111:16 corner[2] - 25:9, 25:18 corporation[2] 66:23, 67:11 correct[42] - 6:20, 6:25, 7:3, 17:6, 20:10, 21:20, 22:6, 22:9, 26:24, 29:5, 30:3, 34:11, 36:14, 37:18, 38:19, 43:22, 44:2, 44:20, 47:15, 48:18, 64:3, 64:12, 64:22, 64:23, 65:1, 65:2, 65:4, 65:5, 67:21, 68:16, 70:5, 73:11, 74:5, 77:24, 84:17, 86:25, 93:5, 93:25, 103:15, 125 108:18, 108:19, 111:8 corrections[2] 122:6, 122:20 correctly[2] - 64:22, 98:22 cost[1] - 89:17 costs[3] - 86:9, 116:6, 117:5 Counsel[2] - 2:6, 2:9 counsel[19] - 13:15, 14:25, 21:2, 46:7, 46:9, 46:12, 46:13, 61:11, 62:18, 62:23, 63:1, 63:6, 105:6, 107:3, 107:4, 121:9, 121:11 counterclaim[1] 44:18 County[1] - 43:13 COUNTY[2] - 120:2, 121:2 couple[1] - 68:8 course[6] - 19:7, 37:20, 46:22, 67:7, 80:15, 100:18 coursework[1] - 81:8 COURT[20] - 1:1, 5:1, 5:5, 19:19, 32:10, 48:14, 51:24, 59:18, 69:14, 79:9, 79:13, 83:12, 83:14, 86:3, 102:20, 105:1, 106:17, 107:14, 107:20, 109:8 court[29] - 15:13, 15:21, 19:25, 20:3, 24:3, 26:12, 26:23, 27:3, 27:4, 28:7, 29:14, 30:24, 32:11, 32:18, 32:22, 42:23, 45:21, 45:24, 69:15, 81:13, 97:13, 101:22, 102:24, 103:3, 103:7, 103:15, 106:19, 112:11 court's[1] - 54:6 cover[1] - 90:1 crass[1] - 116:4 created[9] - 63:9, 66:22, 67:11, 67:14, 75:22, 76:14, 77:19, 110:25, 114:20 creating[1] - 67:4 credibility[3] - 82:7, 84:7, 105:8 creditor[5] - 23:19, 60:7, 60:8, 60:11, 112:19 creditors[3] - 14:21, 59:23, 112:23 criminally[1] - 89:24 crook[2] - 99:11, 99:14 current[5] - 7:13, 7:16, 7:19, 30:6 cut[13] - 74:24, 74:25, 75:4, 75:7, 75:11, 75:12, 75:17, 117:12, 118:2, 118:20, 119:5, 119:14 cutting[1] - 118:7 D Daewoo[3] - 44:10, 44:11, 44:13 dan[3] - 50:24, 54:15, 77:1 Dan[3] - 55:2, 57:1, 76:23 DANIEL[1] - 2:9 data[2] - 51:7, 51:8 date[5] - 37:8, 76:6, 78:24, 91:10, 122:6 Date[1] - 122:23 DATE[1] - 1:11 DATED[1] - 121:18 dates[4] - 7:25, 91:11, 94:17, 94:18 days[2] - 8:6, 67:8 DCA[3] - 80:23, 81:12, 86:14 DCF[1] - 86:13 dead[1] - 11:3 deal[2] - 14:12, 14:14 dealing[4] - 80:7, 85:5, 87:24, 88:9 Deborah[1] - 5:14 DEBORAH[1] - 1:5 debt[2] - 27:18 debtor[1] - 60:6 debtor's[3] - 54:1, 54:14, 56:14 debtors[1] - 36:9 Debtors[2] - 1:6, 2:6 December[1] - 40:12 decide[2] - 17:24, 23:1 decided[1] - 13:9 decision[2] - 86:15, 95:9 declaration[1] - 36:8 declare[1] - 36:12 deep[1] - 89:11 deeper[1] - 89:11 Deerfield[2] - 2:4, 66:24 defendants[2] 101:20, 107:1 define[2] - 70:9, 100:20 definition[1] - 99:8 definitive[1] - 79:18 delightful[1] - 101:4 demanded[2] - 115:6, 115:7 demanding[2] 115:17, 117:5 demands[1] - 116:5 Demartini[6] - 83:10, 83:17, 95:19, 115:2, 115:6, 115:25 denied[1] - 75:25 Denise[12] - 79:3, 79:4, 83:10, 83:17, 92:18, 95:19, 115:2, 115:5, 115:24, 116:20, 117:3 deny[1] - 69:25 department[1] - 25:23 departure[2] - 105:9, 106:6 DEPONENT[37] 13:19, 14:1, 14:4, 18:19, 19:21, 20:16, 25:2, 45:14, 46:1, 50:24, 51:12, 51:16, 58:13, 58:19, 58:25, 62:10, 62:14, 72:4, 79:11, 79:15, 83:13, 83:16, 84:18, 85:24, 86:1, 86:5, 97:5, 105:3, 106:18, 109:10, 113:8, 117:22, 118:18, 119:5, 119:9, 119:14, 119:17 depose[2] - 96:23, 97:23 DEPOSITION[1] - 1:9 deposition[18] - 2:5, 13:8, 27:21, 27:22, 28:19, 29:21, 33:11, 33:15, 35:7, 41:24, 49:15, 51:11, 97:24, 100:9, 119:21, 121:6, 122:5, 122:20 depravity[1] - 41:2 derivative[1] - 110:11 described[2] - 6:20, 105:25 DESCRIPTION[1] 4:2 description[1] 109:21 Desouza[3] - 49:19, 49:20, 52:5 DESOUZA[14] - 2:9, 48:22, 49:1, 50:1, 51:9, 51:14, 51:22, 55:4, 55:20, 59:5, 77:4, 117:18, 119:3, 119:19 destroy[2] - 93:9, 93:19 details[2] - 8:20, 75:7 differences[1] - 95:15 different[7] - 51:9, 51:15, 65:20, 68:8, 77:20, 78:25, 103:21 difficult[4] - 16:19, 33:24, 56:9, 75:2 difficulty[1] - 56:20 Dimartini[1] - 79:3 dinner[1] - 18:1 direct[1] - 116:3 direction[1] - 67:25 directly[5] - 23:16, 33:4, 33:7, 113:11, 113:14 director[1] - 67:14 directors[1] - 105:21 disclose[1] - 63:8 disclosing[1] - 42:22 disclosure[2] - 62:17, 62:21 discover[1] - 112:23 discussed[4] - 80:3, 80:10, 85:17, 85:18 discussion[4] - 14:2, 53:20, 92:15, 92:17 Discussion[3] - 51:2, 63:23, 119:21 discussions[4] 13:25, 46:15, 83:1, 92:17 dismiss[8] - 30:15, 30:25, 61:4, 62:3, 62:4, 62:6, 62:11, 114:11 dismissed[5] - 30:11, 30:12, 30:13, 30:24, 101:22 dispute[2] - 60:7, 60:10 disputed[2] - 23:19, 117:2 disputes[1] - 60:6 disputing[1] - 78:13 distributed[1] - 94:12 District[1] - 5:15 DISTRICT[1] - 1:1 divined[1] - 46:5 DIVISION[1] - 1:2 docs[1] - 59:14 document[6] - 55:9, 58:3, 58:7, 58:12, 77:3, 78:4 documents[33] - 9:2, 49:16, 51:16, 51:17, 52:1, 52:3, 52:15, 52:22, 53:24, 54:8, 54:12, 54:16, 55:7, 55:8, 55:11, 56:2, 56:11, 56:12, 56:15, 56:24, 57:2, 61:15, 61:18, 73:4, 73:5, 78:2, 78:9, 78:11, 104:5, 104:9, 108:11, 108:12, 112:15 done[7] - 53:19, 100:23, 113:9, 118:6, 119:5, 119:6 down[17] - 17:4, 17:5, 17:16, 20:9, 20:14, 50:15, 50:25, 62:15, 67:3, 85:23, 90:17, 94:18, 100:12, 100:15, 100:18, 103:1, 109:9 draft[3] - 69:18, 69:19, 115:7 draw[2] - 42:13, 42:19 Drive[1] - 2:3 drive[33] - 17:4, 17:5, 17:9, 17:14, 17:15, 17:24, 44:7, 50:6, 51:4, 51:6, 51:9, 51:15, 51:20, 52:4, 52:6, 52:22, 54:8, 54:16, 54:18, 54:21, 54:22, 55:1, 55:14, 55:16, 56:1, 56:20, 59:3, 63:17, 63:22, 73:6, 73:7, 76:24, 77:2 drives[1] - 17:11 driving[2] - 17:16, 17:21 drove[5] - 16:12, 16:14, 16:24, 17:22, 44:6 duality[1] - 41:1 duly[2] - 5:7, 120:6 during[6] - 9:4, 43:14, 67:18, 71:7, 71:25, 91:15 E e-mail[18] - 76:15, 76:21, 78:20, 79:24, 84:20, 84:23, 87:2, 89:2, 89:4, 92:16, 95:24, 96:10, 96:13, 96:17, 106:15, 106:21, 115:19, 117:3 e-mails[1] - 68:7 early[2] - 80:3, 82:25 126 earned[2] - 115:18, 116:7 earth[1] - 14:7 easier[1] - 77:17 easily[1] - 28:25 East[1] - 1:13 eating[1] - 55:19 echoes[1] - 105:7 Ed[1] - 84:4 editors[1] - 94:11 Edward[2] - 5:14, 5:19 EDWARD[5] - 1:9, 3:2, 5:6, 120:5, 122:2 EDWARDS[1] - 1:4 effect[2] - 95:16, 111:13 effort[2] - 8:11, 93:7 either[3] - 18:19, 50:3, 89:25 elsewhere[2] - 85:8, 85:9 emanate[1] - 31:7 emanated[2] - 97:15, 98:16 employed[1] - 71:2 employee[3] - 115:2, 121:9, 121:10 employment[6] 67:9, 68:3, 70:24, 71:10, 72:1, 84:17 encrypted[1] - 55:16 end[4] - 27:2, 92:8, 92:10, 106:11 ended[1] - 117:15 ends[1] - 14:7 engage[3] - 79:7, 79:16, 85:11 engaged[1] - 104:7 engaging[1] - 83:6 English[1] - 92:14 enhance[2] - 86:21, 87:3 enthusiastic[1] 80:14 entirely[2] - 36:24, 37:21 entities[1] - 23:5 entitled[2] - 12:9, 28:23 entries[1] - 73:14 ERROR[1] - 122:8 error[1] - 110:3 errors[1] - 122:5 Esquire[2] - 2:6, 2:9 establishment[5] 88:15, 89:7, 89:8, 89:14, 90:1 estate[2] - 42:17, 44:23 ethical[2] - 95:14, 105:7 events[1] - 71:25 evidence[1] - 107:18 evidenced[1] - 117:6 exact[8] - 8:20, 9:6, 70:7, 70:8, 70:16, 70:18, 80:22, 105:16 exactly[8] - 5:23, 6:9, 7:25, 11:23, 19:4, 19:24, 55:11, 98:7 exam[12] - 11:21, 16:21, 22:22, 22:25, 23:2, 23:5, 45:16, 74:6, 74:7, 76:4, 78:8, 107:19 EXAMINATION[2] 3:3, 5:9 examination[9] 1:15, 5:12, 10:15, 14:9, 29:13, 29:16, 48:17, 49:16, 112:20 examined[1] - 5:8 example[7] - 16:16, 17:5, 38:8, 38:9, 88:3, 89:10, 89:20 except[1] - 43:7 exchange[8] - 84:20, 84:23, 95:24, 96:10, 96:13, 109:21, 115:19, 117:3 exchanged[1] 106:21 exclusively[2] - 85:4, 87:23 excuse[1] - 30:10 executive[1] - 67:14 Exhibit[9] - 72:3, 72:5, 72:6, 74:17, 97:10, 107:23, 108:15, 108:17 exhibit[3] - 72:8, 73:21, 110:23 Exhibits[1] - 107:16 EXHIBITS[1] - 4:1 expand[1] - 12:22 expect[1] - 57:12 experience[1] - 88:14 Expires[2] - 120:15, 121:24 explaining[2] - 116:4, 116:14 explore[1] - 12:9 explosive[1] - 106:6 express[1] - 89:4 expressed[6] - 80:25, 81:25, 85:16, 88:10, 106:9 expressing[1] - 89:2 expressive[1] 105:12 extraordinarily[2] 41:11, 66:16 extraordinary[1] 41:4 F fact[9] - 82:1, 82:7, 94:4, 112:18, 115:3, 115:16, 115:22, 116:24, 117:4 facts[14] - 60:14, 60:15, 80:23, 80:24, 85:15, 86:12, 89:10, 89:16, 112:3, 114:18, 115:12, 118:1, 118:2, 118:8 factual[2] - 114:9, 114:10 factually[1] - 61:1 faculty[1] - 81:7 fair[2] - 88:14, 104:10 fallible[1] - 109:25 false[3] - 31:13, 31:15, 32:25 familiar[7] - 47:25, 73:2, 73:16, 75:20, 75:23, 94:19, 110:25 family[1] - 39:1 far[15] - 34:22, 41:9, 52:1, 61:1, 67:10, 75:19, 83:2, 87:12, 88:18, 89:25, 110:5, 112:12, 115:17, 117:5, 117:10 fashion[1] - 8:1 fast[1] - 86:2 federal[1] - 101:22 feelings[1] - 106:12 fees[5] - 114:5, 115:18, 116:6, 117:5, 117:25 few[6] - 12:3, 56:9, 66:24, 88:3, 111:24, 112:9 FF078246[2] - 120:14, 121:23 file[3] - 13:5, 77:19, 115:9 filed[17] - 5:13, 30:15, 30:17, 30:21, 38:13, 44:25, 45:6, 59:22, 61:4, 62:5, 62:11, 89:6, 89:7, 101:15, 101:16, 101:18, 116:25 files[1] - 57:12 filibuster[1] - 118:17 filibustered[1] 118:19 filibustering[1] 118:21 filing[5] - 36:8, 37:8, 42:15, 89:23, 115:10 filled[3] - 37:15, 45:1, 45:3 filling[1] - 42:11 final[1] - 69:19 financed[2] - 114:25, 115:1 finances[11] - 10:13, 11:2, 11:12, 12:6, 12:23, 12:25, 14:6, 14:21, 14:24, 112:10, 112:16 financial[3] - 10:11, 24:12, 80:8 financially[2] - 7:6, 121:11 fine[9] - 6:12, 7:16, 57:8, 59:16, 76:19, 92:24, 96:22, 99:20, 111:23 finish[7] - 57:7, 102:23, 112:13, 114:13, 114:16, 116:9, 119:3 finished[2] - 73:24, 103:11 fired[1] - 89:9 firm[23] - 79:8, 79:16, 80:4, 80:5, 80:8, 82:11, 83:6, 83:7, 85:2, 85:19, 86:9, 90:12, 91:5, 91:14, 114:24, 115:1, 115:3, 115:16, 116:5, 116:18, 116:19, 116:25, 117:4 Firm[11] - 80:14, 85:3, 85:4, 85:22, 86:7, 86:8, 86:19, 87:23, 104:7, 106:2, 114:19 firm's[1] - 85:20 firms[3] - 80:13, 83:8, 83:21 first[17] - 8:25, 12:18, 12:21, 16:24, 20:21, 38:18, 40:3, 69:18, 75:5, 76:23, 82:13, 86:20, 88:4, 92:21, 98:18, 101:2, 104:2 First[2] - 105:6, 105:22 fishing[1] - 23:3 fit[1] - 40:24 five[3] - 34:8, 83:20, 99:24 flawed[2] - 40:15, 40:21 flaws[1] - 40:23 flip[1] - 72:16 FLORIDA[3] - 1:1, 120:2, 121:2 Florida[16] - 1:14, 1:17, 1:18, 2:4, 2:7, 2:10, 5:15, 5:20, 20:10, 20:12, 67:4, 105:6, 114:21, 115:4, 120:14, 121:23 flow[2] - 8:1, 8:8 folder[3] - 77:18, 77:23, 78:1 follow[1] - 81:19 following[1] - 116:17 follows[2] - 5:8, 88:23 food[2] - 18:25, 19:24 FOR[2] - 4:1, 122:8 foreclosure[3] - 6:20, 7:2, 7:5 foregoing[2] - 36:13, 121:6 Forest[1] - 5:19 forgot[1] - 79:11 format[1] - 56:6 formatted[1] - 59:3 forms[3] - 81:5, 81:6, 81:8 Fort[1] - 2:10 forth[3] - 67:7, 68:8, 71:7 Foundation[15] 30:22, 44:19, 45:6, 60:6, 66:10, 66:21, 67:3, 94:15, 95:13, 96:25, 105:6, 105:22, 106:1, 114:20, 115:5 foundation[13] 24:17, 67:5, 67:6, 67:13, 80:8, 82:6, 83:23, 84:6, 86:21, 87:4, 89:6, 115:12 foundation's[2] 82:6, 84:7 four[2] - 83:19, 100:1 Fourth[3] - 80:23, 81:11, 86:13 FPR[3] - 1:16, 120:13, 121:22 frame[4] - 35:22, 43:14, 61:19, 84:19 FRANK[1] - 2:6 frank[1] - 113:8 Frank[11] - 13:19, 59:16, 66:2, 72:12, 76:10, 98:13, 99:12, 104:22, 108:14, 113:10, 113:25 frankly[1] - 16:25 frequently[1] - 17:19 127 Friday[1] - 79:6 friendly[1] - 81:24 fuck[8] - 105:10, 108:4, 109:4, 109:6, 109:7, 110:12, 111:4 full[2] - 109:12, 118:8 funded[4] - 111:25, 114:4, 115:4, 117:24 funding[1] - 67:5 FURTHER[1] - 121:8 future[1] - 77:17 G gain[2] - 10:15, 112:21 gaining[1] - 45:17 garage[1] - 115:23 generally[5] - 70:10, 73:9, 73:10, 109:15, 110:7 generate[1] - 114:23 generating[7] 111:25, 112:4, 113:17, 113:23, 115:16, 117:7, 117:24 generosity[1] - 41:5 given[10] - 9:6, 11:10, 29:8, 36:25, 56:4, 80:13, 80:17, 81:25, 83:21, 121:7 glad[1] - 28:24 goal[1] - 29:1 Gomez[3] - 57:18, 57:23, 58:1 gosh[1] - 94:2 government[5] - 82:4, 82:8, 84:5, 85:19, 99:2 great[3] - 71:13, 95:21, 96:14 greater[1] - 114:21 Greg[6] - 47:5, 82:1, 82:9, 84:4, 85:19, 105:7 Group[2] - 2:3, 101:3 guess[7] - 49:11, 52:17, 82:18, 90:9, 100:9, 103:14, 118:6 Gulfstream[4] - 74:9, 89:19, 101:7, 101:19 guy[2] - 99:10, 101:4 guys[2] - 51:19, 77:18 gyrations[1] - 9:1 H habit[1] - 95:1 half[1] - 63:19 halfway[1] - 104:21 hall[4] - 38:18, 38:21, 40:3, 41:25 hand[5] - 49:24, 110:6, 111:15, 111:17, 120:7 hands[1] - 8:3 hang[5] - 11:16, 35:21, 76:3 happy[26] - 12:24, 14:10, 14:19, 29:3, 50:20, 55:16, 55:24, 56:2, 56:4, 56:6, 56:21, 56:25, 57:2, 57:5, 58:20, 58:21, 58:22, 59:1, 97:1, 97:5, 112:12, 112:14, 118:9, 118:12, 119:10 harass[1] - 89:22 hard[22] - 51:4, 52:7, 52:22, 53:19, 54:8, 54:16, 54:18, 54:21, 54:22, 55:1, 55:14, 55:16, 56:1, 56:20, 59:3, 63:17, 63:22, 73:6, 73:7, 76:24, 77:2, 106:12 head[10] - 16:25, 31:18, 33:9, 34:4, 36:21, 54:4, 55:9, 69:21, 99:3, 101:14 hear[2] - 110:7, 117:19 heard[1] - 117:18 hearing[1] - 82:23 heinous[2] - 41:3, 41:4 help[9] - 14:23, 30:14, 56:1, 56:5, 58:10, 59:1, 92:25, 93:1 helpful[3] - 42:21, 71:12, 71:14 herein[1] - 5:7 hereto[1] - 122:21 hidden[1] - 112:23 hide[1] - 112:24 highly[2] - 82:2, 84:5 HILLSBOROUGH[2] 120:2, 121:2 himself[8] - 105:11, 108:4, 109:4, 109:6, 109:7, 110:12, 111:4 hire[1] - 90:12 hired[2] - 67:15, 91:5 hold[3] - 14:1, 48:11, 78:23 holder[1] - 8:2 holding[1] - 59:23 home[4] - 20:20, 67:3, 108:23, 108:25 honest[3] - 11:11, 39:12, 70:5 hoop[1] - 49:24 hoped[1] - 106:9 Hopkins[3] - 47:21, 47:24, 48:3 horrible[2] - 41:10, 41:13 hotel[2] - 105:19, 115:23 hours[1] - 19:7 house[4] - 6:19, 6:24, 7:6, 7:9 housing[1] - 18:25 I idea[7] - 20:9, 20:11, 37:22, 38:10, 44:12, 103:16, 103:19 identical[2] - 80:24, 86:12 IDENTIFICATION[1] 4:1 identification[5] 72:6, 74:17, 97:11, 107:16, 107:23 imagine[3] - 61:24, 101:16, 101:17 immediately[4] 30:25, 36:5, 36:20, 115:22 important[2] - 80:4, 82:8 imposed[1] - 117:1 impression[1] - 63:9 impressions[2] 62:15, 62:20 impropriety[1] - 80:7 imprudent[1] - 80:15 imprudently[2] 101:23, 101:25 in-person[1] - 92:17 Inc[3] - 2:3, 44:19, 66:10 inclined[2] - 79:7, 79:14 include[1] - 122:20 including[3] - 93:10, 93:22, 96:21 incorrect[1] - 21:20 INDEX[1] - 3:1 indicated[3] - 36:23, 58:2, 122:6 individually[2] 94:25, 107:22 induced[1] - 21:10 inflection[1] - 92:10 information[7] - 9:5, 9:6, 11:20, 13:21, 24:17, 36:15, 73:8 inspect[2] - 53:5 instances[1] - 42:9 instead[2] - 11:18, 26:9 instruct[1] - 23:24 instructing[1] 113:12 INSTRUCTIONS[1] 122:3 intended[4] - 89:3, 95:17, 112:20, 112:22 interaction[1] - 23:15 Intercontinental[1] 105:18 interest[4] - 80:8, 80:25, 81:25, 85:16 interested[3] - 86:10, 86:16, 121:12 interesting[1] - 80:20 interject[1] - 45:10 interrupts[1] - 102:23 invite[3] - 18:1, 18:2, 89:25 invited[2] - 17:25, 67:3 involve[1] - 67:9 involved[3] - 67:2, 82:22, 88:13 iron[1] - 59:14 irreconcilable[1] 95:14 IRS[4] - 85:5, 87:1, 87:17, 87:24 issue[7] - 56:22, 56:25, 84:25, 85:2, 89:5, 92:19, 115:20 issues[5] - 8:1, 8:8, 82:3, 82:8, 99:2 it'll[2] - 50:1, 75:1 itself[1] - 122:5 J Jackson[1] - 79:5 January[3] - 66:22, 67:12, 121:18 Joanne[1] - 11:9 job[2] - 30:22, 67:10 Joe[2] - 59:10, 72:12 Joel[12] - 5:13, 5:19, 13:2, 51:11, 54:15, 76:8, 77:11, 78:18, 79:2, 87:1, 94:19, 116:21 JOEL[6] - 1:4, 1:9, 3:2, 5:6, 120:5, 122:2 John[2] - 84:3, 115:24 Johnson[1] - 1:13 Jonathan[3] - 106:2, 115:25, 116:20 judge[3] - 18:14, 48:24, 58:2 Judge[4] - 10:21, 13:6, 51:18, 63:7 July[3] - 94:21, 108:8 June[19] - 67:16, 76:8, 76:12, 76:13, 76:15, 76:18, 78:19, 78:23, 78:25, 84:8, 84:14, 84:21, 91:15, 94:20, 95:19, 104:20, 104:21, 104:25, 105:4 juvie[1] - 93:3 K Kaney[1] - 84:3 keep[8] - 8:24, 13:7, 28:17, 40:6, 66:25, 67:1, 86:2, 113:19 Kelly[1] - 79:5 Kennedy[1] - 105:19 kept[2] - 9:10, 115:17 kick[1] - 86:1 kind[4] - 44:9, 86:23, 90:17, 103:25 kindly[4] - 15:10, 30:20, 56:11, 61:9 kindness[1] - 41:5 kinds[2] - 38:25, 40:6 knowing[1] - 70:16 knowingly[1] - 101:5 knowledge[7] 36:15, 37:1, 54:7, 55:13, 64:14, 64:17, 74:22 known[1] - 84:5 L lack[3] - 36:25, 68:15, 97:14 lady[1] - 32:9 laid[2] - 114:10, 114:11 Lakeland[24] - 5:20, 10:1, 20:21, 21:4, 21:6, 21:8, 21:10, 21:13, 21:17, 21:22, 22:5, 22:8, 22:11, 22:16, 22:17, 25:8, 25:10, 25:11, 25:19, 26:22, 116:3 landmark[2] - 85:20, 86:3 128 language[2] - 74:3, 111:10 laptop[1] - 55:4 large[2] - 80:12, 82:7 Large[3] - 1:18, 120:14, 121:23 largest[1] - 82:11 last[14] - 9:9, 14:19, 20:8, 25:17, 28:5, 46:1, 48:25, 51:10, 56:19, 76:23, 79:17, 100:21, 102:20, 102:21 late[1] - 90:16 Lauderdale[1] - 2:10 law[24] - 79:8, 79:16, 80:4, 80:5, 80:13, 82:11, 83:6, 83:7, 83:8, 83:21, 85:2, 85:19, 89:1, 90:12, 91:14, 114:24, 115:1, 115:3, 115:16, 116:5, 116:18, 116:19, 116:25, 117:4 Law[11] - 80:14, 85:3, 85:4, 85:22, 86:7, 86:8, 86:18, 87:23, 104:7, 106:2, 114:19 lawsuit[14] - 11:8, 23:3, 27:16, 45:5, 45:12, 46:2, 63:3, 63:5, 63:6, 74:5, 112:19, 115:10, 115:11 lawsuits[11] - 89:6, 89:8, 102:6, 104:8, 114:23, 115:7, 115:9, 115:11, 116:24, 117:1 lawyer[4] - 86:23, 87:11, 88:22, 88:23 lawyer's[1] - 26:10 lawyers[2] - 47:22, 88:20 least[7] - 8:6, 44:20, 80:6, 80:12, 83:7, 85:9, 115:6 leave[5] - 13:8, 20:20, 28:21, 72:13, 106:5 leaving[2] - 31:1, 88:12 lectured[1] - 28:20 left[1] - 30:22 legal[11] - 42:13, 42:20, 46:6, 46:9, 46:11, 46:12, 63:10, 83:23, 112:1, 114:5, 117:25 less[3] - 6:16, 6:17, 6:25 letter[3] - 78:14, 78:18, 79:23 letting[1] - 118:7 level[1] - 11:3 liability[1] - 88:22 licensed[1] - 115:4 life[3] - 39:9, 95:22, 109:1 likely[1] - 79:5 limited[2] - 22:12, 41:24 Lincoln[1] - 105:19 line[6] - 22:22, 25:24, 43:8, 64:16, 102:12, 112:7 lines[1] - 122:6 linked[1] - 99:1 list[2] - 23:20, 37:25 listed[5] - 23:21, 38:5, 45:12, 74:11 literally[1] - 67:13 litigated[1] - 80:21 litigation[7] - 35:7, 41:24, 44:20, 45:15, 86:9, 104:5, 104:10 litigators[1] - 84:6 lived[3] - 5:21, 6:6, 6:24 LLP[1] - 1:13 loan[1] - 9:8 LOCATION[1] - 1:13 LoCicero[14] - 80:24, 81:24, 82:2, 82:5, 84:9, 84:11, 85:11, 90:10, 90:18, 90:19, 90:21, 90:22, 92:20 long-time[1] - 115:2 look[21] - 13:19, 34:5, 38:10, 46:21, 46:22, 49:22, 53:11, 55:6, 58:16, 63:14, 67:8, 72:10, 72:12, 87:14, 98:18, 98:21, 100:6, 109:18, 109:19, 113:8, 119:15 looked[1] - 73:13 looking[6] - 18:23, 33:24, 47:17, 53:12, 59:21, 73:24 looks[8] - 73:1, 73:16, 75:20, 75:23, 76:8, 88:18, 110:25 love[1] - 105:11 lower[1] - 55:18 lunch[1] - 81:18 lying[2] - 82:14, 99:7 M Mac[3] - 53:13, 56:23, 59:3 machine[1] - 55:23 Madison[1] - 1:13 mail[18] - 76:15, 76:21, 78:20, 79:24, 84:20, 84:23, 87:2, 89:2, 89:4, 92:16, 95:24, 96:10, 96:13, 96:17, 106:15, 106:21, 115:19, 117:3 mailed[1] - 49:8 mails[1] - 68:7 main[1] - 17:8 man[4] - 39:12, 41:1, 41:2, 70:5 managerial[1] - 115:2 manner[1] - 37:22 Manson[1] - 41:8 March[1] - 61:15 mark[9] - 22:3, 72:2, 74:16, 82:20, 92:8, 97:7, 97:13, 107:20, 122:5 MARKED[1] - 4:1 marked[7] - 72:6, 74:17, 97:10, 107:13, 107:16, 107:22, 107:23 Martin[4] - 5:11, 111:25, 114:4, 117:24 MARTIN[1] - 2:2 marty[1] - 119:17 Marty[21] - 12:16, 13:20, 14:4, 14:18, 31:6, 59:6, 85:1, 96:18, 97:17, 106:2, 108:3, 109:4, 109:6, 109:7, 109:11, 110:10, 110:11, 111:4, 118:18, 119:3 massive[1] - 14:6 matter[2] - 89:10, 89:20 mattered[1] - 115:9 mean[23] - 12:21, 16:23, 24:5, 50:5, 51:14, 58:5, 60:18, 60:22, 66:4, 66:6, 66:7, 75:20, 78:2, 80:24, 89:5, 89:9, 94:7, 97:20, 98:7, 100:10, 102:6, 107:7, 108:21 meanie[1] - 104:23 means[3] - 25:5, 25:7, 45:17 meanwhile[1] - 27:22 media[1] - 94:8 meet[31] - 9:25, 12:13, 12:14, 15:25, 16:4, 16:6, 16:13, 16:15, 16:17, 16:24, 17:2, 17:16, 17:19, 17:20, 17:22, 17:24, 17:25, 20:21, 20:22, 22:20, 24:6, 25:1, 25:6, 25:18, 25:21, 25:23, 26:5, 26:10, 26:12, 29:14, 30:23 meeting[10] - 21:17, 27:5, 38:15, 71:17, 104:4, 105:21, 107:7, 107:8, 107:10, 115:22 meetings[1] - 114:22 meets[3] - 104:24, 105:4, 105:5 member[2] - 82:11, 101:8 members[2] - 83:11, 83:18 memorandum[4] 67:21, 67:23, 68:6, 69:7 memory[5] - 35:9, 47:17, 71:13, 71:18, 71:24 men[2] - 41:3, 41:4 MENDOZA[4] - 1:16, 120:13, 121:4, 121:22 mental[3] - 62:15, 62:20, 63:9 mention[1] - 92:7 mentioned[4] - 34:14, 35:1, 85:15, 99:22 MEO[1] - 105:10 merit[3] - 46:3, 46:5, 46:8 meritless[1] - 46:2 met[25] - 9:24, 12:2, 12:15, 16:11, 16:16, 21:6, 22:11, 22:16, 22:17, 24:10, 24:11, 24:13, 25:5, 25:8, 25:9, 25:15, 38:20, 67:4, 81:18, 83:18, 101:2, 104:3, 105:25, 107:5 MIDDLE[1] - 1:1 Middle[1] - 5:15 might[10] - 30:2, 34:6, 58:14, 64:7, 67:8, 73:10, 77:7, 110:2 mind[7] - 35:13, 35:16, 43:18, 43:20, 85:10, 88:21, 115:12 mine[4] - 50:2, 50:3, 53:12, 106:11 minute[3] - 15:4, 48:11, 63:20 minutes[2] - 59:6, 88:3 mistaken[1] - 48:2 model[1] - 51:13 moderately[1] - 95:12 moderately-tone[1] 95:12 modify[1] - 9:8 Moganen[1] - 84:4 Monday[1] - 106:23 money[19] - 8:19, 8:24, 9:10, 11:11, 33:3, 40:6, 42:1, 60:7, 60:8, 60:11, 60:12, 60:16, 60:17, 60:18, 60:23, 60:25, 61:2, 89:22, 117:8 month[1] - 83:20 months[5] - 9:7, 19:5, 66:24, 100:21, 100:23 morning[1] - 119:2 mortgage[5] - 7:9, 7:11, 8:2, 9:1, 9:3 most[10] - 41:3, 41:4, 46:23, 56:2, 56:24, 79:5, 82:8, 86:16, 96:6, 96:7 Mother[1] - 41:7 motion[7] - 13:5, 61:4, 62:3, 62:4, 62:5, 62:11, 114:10 motivations[1] 22:14 mouth[3] - 40:4, 82:23, 105:17 move[5] - 15:2, 21:1, 32:3, 59:12, 78:22 MR[403] - 5:10, 6:13, 6:14, 7:12, 7:15, 10:7, 10:10, 10:18, 11:16, 11:23, 11:25, 12:2, 12:4, 12:7, 12:10, 12:11, 12:12, 12:17, 12:19, 12:20, 13:1, 13:15, 13:16, 13:24, 14:3, 14:14, 14:16, 15:3, 15:7, 15:8, 15:15, 15:19, 15:23, 16:20, 17:3, 17:10, 17:12, 18:6, 18:10, 18:11, 18:12, 18:13, 18:15, 18:17, 18:21, 19:23, 20:2, 20:5, 20:17, 20:19, 21:2, 21:3, 21:5, 22:21, 22:23, 22:24, 23:6, 23:7, 23:10, 23:13, 23:15, 23:18, 23:23, 24:1, 24:7, 129 24:9, 24:15, 24:20, 24:22, 24:23, 24:25, 25:4, 25:12, 25:14, 25:24, 26:2, 26:16, 26:17, 26:18, 26:19, 26:20, 27:11, 27:20, 28:1, 28:3, 28:5, 28:10, 28:15, 29:20, 29:22, 32:5, 32:6, 32:8, 32:13, 32:16, 32:20, 32:24, 34:12, 34:13, 34:20, 35:21, 35:23, 35:24, 36:1, 36:2, 36:6, 36:10, 36:11, 37:7, 37:10, 37:11, 37:14, 37:16, 38:2, 38:4, 38:6, 38:13, 38:17, 39:16, 39:17, 39:19, 39:20, 39:21, 41:15, 41:20, 41:22, 42:8, 42:25, 43:5, 43:6, 43:9, 43:10, 43:11, 45:10, 45:19, 45:23, 46:4, 46:13, 46:14, 46:17, 47:10, 47:11, 47:13, 47:14, 48:6, 48:8, 48:9, 48:12, 48:15, 48:22, 48:23, 49:1, 49:2, 49:3, 49:5, 49:7, 49:9, 49:10, 49:13, 49:14, 49:18, 49:20, 49:22, 49:25, 50:1, 50:3, 50:9, 50:10, 50:11, 50:18, 50:22, 51:1, 51:3, 51:9, 51:14, 51:22, 51:23, 51:25, 52:8, 52:9, 52:11, 52:13, 52:14, 52:16, 52:17, 52:23, 53:8, 53:9, 53:15, 54:2, 54:10, 54:11, 54:15, 54:20, 55:2, 55:4, 55:5, 55:6, 55:7, 55:20, 56:10, 57:6, 57:8, 57:11, 57:14, 57:16, 57:18, 58:4, 58:6, 58:7, 58:8, 58:14, 58:16, 58:17, 58:24, 59:5, 59:7, 59:9, 59:13, 59:16, 59:19, 59:20, 60:1, 60:2, 60:3, 60:4, 60:19, 60:20, 60:21, 61:11, 61:12, 61:14, 61:17, 61:23, 62:1, 62:4, 62:5, 62:7, 62:8, 62:12, 62:18, 62:19, 62:20, 62:22, 62:25, 63:12, 63:13, 63:19, 63:21, 63:24, 63:25, 64:8, 64:10, 64:11, 65:10, 65:11, 65:12, 65:14, 65:17, 65:19, 65:21, 65:22, 66:1, 66:5, 66:19, 66:25, 67:17, 69:11, 69:17, 70:9, 70:10, 70:13, 70:22, 70:23, 71:4, 72:2, 72:5, 72:7, 72:9, 72:11, 73:23, 74:4, 74:7, 74:10, 74:13, 74:15, 74:16, 74:20, 76:3, 76:5, 76:7, 76:9, 76:10, 77:1, 77:4, 77:5, 77:8, 79:20, 84:1, 84:16, 85:23, 85:25, 86:22, 87:7, 87:9, 87:10, 90:3, 90:4, 90:8, 91:10, 91:12, 91:13, 91:15, 91:16, 91:17, 91:20, 91:21, 91:22, 91:23, 91:24, 91:25, 92:13, 92:23, 93:11, 93:13, 93:14, 94:17, 94:19, 94:23, 95:1, 95:3, 95:7, 97:3, 97:7, 97:12, 98:12, 98:13, 98:14, 98:15, 98:18, 98:21, 98:23, 99:8, 99:10, 99:13, 99:19, 100:5, 100:8, 100:10, 100:14, 100:16, 100:17, 101:9, 101:10, 102:12, 102:15, 102:16, 102:19, 102:21, 103:1, 103:5, 103:6, 103:9, 103:11, 103:12, 104:18, 104:20, 104:21, 104:22, 105:13, 107:2, 107:13, 107:17, 107:24, 108:1, 108:12, 108:14, 108:16, 108:24, 109:2, 109:14, 113:2, 113:5, 113:7, 113:10, 113:13, 113:15, 113:24, 113:25, 114:3, 117:18, 117:20, 118:4, 118:15, 118:16, 118:24, 119:1, 119:3, 119:4, 119:7, 119:11, 119:16, 119:19 Mullins[1] - 84:4 multiple[2] - 21:18, 49:16 must[1] - 105:9 N name[7] - 5:11, 5:17, 46:20, 46:25, 99:21, 99:22, 109:12 name's[1] - 47:25 named[2] - 48:3, 82:23 names[2] - 46:18, 47:4 narrow[5] - 65:10, 65:15, 66:1, 92:13, 94:18 NE[1] - 2:10 necessarily[3] - 78:3, 80:11, 106:6 necessary[2] - 28:24, 55:25 need[18] - 21:24, 24:16, 33:22, 34:15, 34:16, 35:8, 47:17, 51:20, 52:25, 57:24, 72:17, 80:11, 81:7, 82:13, 86:17, 87:15, 106:5, 112:6 never[4] - 8:17, 29:18, 93:6, 93:7 new[1] - 48:22 Newport[1] - 2:3 newspaper[9] - 94:3, 94:11, 94:16, 97:14, 98:16, 98:19, 98:24, 107:15, 107:21 newspapers[4] 93:25, 94:2, 94:5, 94:7 next[7] - 29:14, 75:14, 76:18, 88:20, 103:1, 103:2, 116:20 nice[1] - 99:11 Nick[7] - 95:24, 96:1, 96:3, 96:10, 96:14, 106:21, 115:19 nigger[2] - 96:4, 96:17 NO[1] - 4:2 Nobles[7] - 80:21, 81:10, 85:12, 85:15, 86:10, 86:11 none[10] - 35:13, 35:16, 36:4, 36:19, 37:23, 43:18, 43:20 nonpriority[1] - 59:24 nonsensical[7] 11:9, 33:2, 45:5, 45:7, 46:2, 88:17, 89:11 Notary[3] - 1:17, 120:13, 121:22 note[2] - 63:8, 122:5 noted[1] - 122:21 notes[16] - 33:22, 33:24, 34:5, 34:16, 34:23, 35:9, 38:10, 46:21, 46:23, 47:18, 61:3, 61:7, 61:23, 62:3, 63:16, 73:5 nothing[7] - 5:3, 17:11, 37:2, 45:8, 73:15, 115:15, 117:7 Notice[1] - 1:15 notice[3] - 48:16, 49:4, 49:15 Number[2] - 120:14, 121:23 number[18] - 5:15, 9:23, 46:16, 56:12, 60:1, 74:23, 80:1, 80:5, 80:12, 82:7, 86:14, 88:14, 92:14, 94:10, 104:18, 106:3, 106:25, 117:23 numbered[1] - 75:1 O O'[3] - 2:5, 5:11, 50:14 O'BOYLE[227] - 2:2, 5:10, 6:14, 7:15, 10:10, 10:18, 11:23, 12:2, 12:7, 12:11, 12:12, 12:19, 13:1, 13:15, 14:16, 15:7, 15:8, 15:15, 15:19, 15:23, 17:3, 17:12, 18:10, 18:12, 18:15, 18:21, 19:23, 20:2, 20:5, 20:17, 20:19, 21:2, 21:5, 22:23, 23:6, 23:10, 23:15, 23:23, 24:7, 24:15, 24:22, 24:23, 25:4, 25:14, 26:2, 26:17, 26:19, 26:20, 27:20, 28:3, 28:10, 29:22, 32:6, 32:8, 32:13, 32:16, 32:20, 32:24, 34:13, 34:20, 35:23, 36:1, 36:6, 36:11, 37:10, 37:14, 37:16, 38:6, 38:17, 39:17, 39:20, 39:21, 41:22, 42:25, 43:6, 43:10, 43:11, 46:4, 46:13, 46:17, 47:11, 47:14, 48:8, 48:9, 48:15, 48:23, 49:2, 49:5, 49:9, 49:10, 49:14, 49:20, 49:25, 50:3, 50:10, 50:18, 51:1, 51:23, 51:25, 52:9, 52:13, 52:16, 52:23, 53:9, 53:15, 54:11, 54:15, 54:20, 55:2, 55:5, 55:7, 56:10, 57:6, 57:11, 57:16, 58:4, 58:7, 58:16, 59:7, 59:9, 59:16, 59:19, 59:20, 60:2, 60:4, 60:20, 60:21, 61:11, 61:14, 61:23, 62:4, 62:7, 62:12, 62:18, 62:20, 62:25, 63:12, 63:19, 63:24, 63:25, 64:10, 64:11, 65:11, 65:12, 65:17, 65:21, 66:1, 66:5, 67:17, 69:17, 70:10, 70:13, 70:23, 71:4, 72:2, 72:5, 72:9, 72:11, 73:23, 74:7, 74:13, 74:16, 74:20, 76:5, 76:7, 76:10, 77:1, 77:5, 77:8, 79:20, 84:1, 86:22, 87:9, 87:10, 90:4, 90:8, 91:12, 91:15, 91:17, 91:21, 91:23, 91:25, 92:23, 93:13, 93:14, 94:19, 95:1, 95:7, 97:7, 97:12, 98:13, 98:15, 98:23, 99:10, 99:19, 100:8, 100:14, 100:17, 101:10, 102:15, 102:19, 102:21, 103:5, 103:11, 103:12, 104:20, 104:22, 105:13, 107:2, 107:13, 107:24, 108:1, 108:14, 108:16, 109:14, 113:5, 113:10, 113:15, 113:25, 114:3, 117:20, 118:4, 118:16, 118:24, 119:4, 119:11, 119:16 O'Boyle[27] - 3:4, 14:4, 31:6, 50:17, 80:13, 85:3, 85:4, 85:22, 86:6, 86:8, 86:18, 87:23, 104:7, 106:2, 106:3, 108:3, 109:6, 109:11, 109:12, 110:10, 111:4, 111:25, 114:4, 114:19, 115:25, 117:24 130 O'Connor[1] - 11:10 OATH[1] - 120:1 oath[17] - 5:7, 6:1, 21:25, 23:20, 29:12, 33:13, 35:10, 45:4, 64:2, 97:18, 97:21, 97:22, 99:16, 109:20, 111:11, 111:19, 118:23 Oath[1] - 3:7 Obama[2] - 16:16, 16:18 object[5] - 10:7, 87:8, 100:10, 107:17, 112:7 objected[4] - 28:1, 57:15, 57:16, 103:9 objecting[5] - 41:17, 98:3, 113:2, 113:3, 113:4 objection[23] - 16:20, 17:10, 18:6, 22:21, 24:9, 25:12, 25:24, 27:11, 29:21, 41:15, 41:16, 43:5, 57:21, 57:25, 58:9, 61:21, 63:15, 76:3, 93:11, 101:9, 102:12, 116:5 objection's[1] - 24:20 objections[2] - 59:15, 116:23 obligation[2] - 46:10, 54:23 obliged[2] - 63:7, 63:8 obtuse[1] - 93:1 obviously[2] - 75:12, 85:6 occurred[1] - 58:5 October[3] - 1:11, 108:9, 120:8 OF[9] - 1:1, 1:9, 3:2, 120:1, 120:2, 120:2, 121:1, 121:2, 121:2 off-campus[1] - 81:9 offer[1] - 102:1 offered[3] - 53:5, 102:2, 107:18 office[12] - 26:10, 26:12, 26:23, 27:3, 27:4, 29:15, 82:24, 88:2, 93:10, 93:20, 96:3, 101:2 offices[1] - 104:3 official[1] - 120:7 old[1] - 82:12 once[3] - 9:24, 15:10, 59:14 one[66] - 11:19, 15:17, 19:23, 24:14, 31:8, 32:17, 32:20, 34:8, 34:12, 34:13, 34:14, 34:25, 35:1, 35:2, 35:3, 35:4, 35:5, 35:6, 38:9, 38:18, 40:3, 42:9, 42:19, 44:15, 45:23, 47:21, 48:22, 48:25, 49:1, 49:2, 51:10, 51:20, 52:24, 55:17, 56:8, 56:19, 63:12, 72:8, 72:9, 75:9, 75:11, 76:16, 76:18, 77:3, 78:19, 80:2, 80:4, 81:23, 82:9, 83:7, 85:12, 85:15, 87:18, 87:21, 96:4, 97:8, 103:1, 105:11, 107:4, 114:1, 115:14, 116:18, 118:18, 118:22 ones[5] - 34:7, 38:9, 57:16, 99:4, 107:21 online[1] - 33:18 open[17] - 10:13, 50:1, 50:2, 50:3, 50:11, 53:6, 53:8, 55:4, 59:3, 82:4, 82:8, 84:5, 85:18, 99:2, 112:24, 114:22, 117:15 open-ended[1] 117:15 opening[1] - 88:15 operate[1] - 81:2 operated[1] - 85:14 opined[1] - 88:24 opinion[5] - 88:22, 101:23, 101:25, 102:1, 102:2 opposed[1] - 116:14 OR[1] - 122:8 oral[1] - 1:15 order[4] - 10:15, 58:1, 71:15, 71:18 organization[1] 114:20 organizations[1] 116:16 original[1] - 110:24 Osiero[1] - 76:1 otherwise[3] - 63:7, 68:14, 110:3 ought[1] - 98:21 outside[4] - 15:5, 45:15, 82:13, 112:22 owe[8] - 60:7, 60:11, 60:12, 60:16, 60:18, 60:24, 61:2 owes[1] - 60:6 own[7] - 59:4, 62:23, 63:1, 63:6, 74:2, 104:5, 104:9 owns[1] - 44:13 P p.m[11] - 1:12, 15:6, 48:13, 59:8, 74:18, 76:15 page[17] - 36:8, 43:8, 43:9, 60:1, 60:2, 64:17, 64:19, 75:4, 75:10, 75:13, 75:14, 75:16, 75:17, 104:18, 117:22, 122:5, 122:6 PAGE[2] - 3:3, 4:2 Page[1] - 3:9 PAGE/ERRATA[1] 122:1 PAGE/LINE[1] - 122:8 pages[4] - 52:22, 74:23, 74:25, 122:7 paid[1] - 117:9 Palm[1] - 43:13 paper[1] - 38:1 paperwork[3] - 42:11, 42:15, 54:5 paragraph[3] - 92:9, 113:16, 113:22 pardon[5] - 26:17, 48:23, 52:13, 91:21, 103:18 parenthetically[1] 92:7 Park[1] - 5:19 parking[1] - 115:23 part[6] - 31:8, 62:1, 62:2, 62:9, 92:16, 95:23 partial[1] - 75:13 participate[1] - 29:3 participated[1] 33:12 particular[6] - 35:1, 56:9, 61:4, 79:22, 79:24, 80:19 particulars[2] - 35:10, 67:9 parties[1] - 121:9 parties'[1] - 121:10 partner[2] - 82:1, 85:20 partners[1] - 82:9 password[1] - 55:17 pay[2] - 8:11, 89:18 payment[6] - 7:19, 8:10, 8:21, 9:12, 30:23, 116:6 payments[8] - 7:13, 7:17, 7:22, 8:8, 8:11, 8:22, 9:4, 9:9 PC[4] - 53:14, 55:23, 56:23, 59:4 PDFs[1] - 56:25 peaches[2] - 55:18, 55:19 penalty[2] - 36:12, 64:13 pending[5] - 15:10, 23:4, 24:24, 45:15, 59:23 penny[1] - 89:17 people[12] - 17:16, 17:19, 40:15, 40:20, 40:23, 82:3, 89:22, 89:23, 93:10, 94:7, 102:3, 117:8 per[2] - 115:7, 117:1 perfectly[1] - 75:12 periodically[1] - 9:4 perjure[2] - 36:16, 36:17 perjury[2] - 36:12, 64:13 person[5] - 39:13, 68:15, 92:17, 116:18, 116:19 personally[3] - 44:24, 71:13, 120:5 pertain[12] - 12:25, 23:2, 23:11, 23:13, 24:9, 27:12, 27:13, 41:16, 45:11, 65:24, 74:4 pertains[12] - 11:18, 12:23, 13:18, 14:23, 16:21, 18:18, 22:24, 23:9, 24:11, 38:4, 61:19, 107:18 Peterson[13] 104:16, 104:25, 105:4, 105:5, 105:15, 108:3, 109:3, 109:22, 110:10, 110:19, 111:3, 111:12, 115:23 Peterson's[3] - 108:9, 108:19, 109:20 petition[1] - 37:12 philosophical[1] 95:15 phone[10] - 9:23, 10:22, 85:1, 95:20, 115:24, 116:1, 116:17 phrase[1] - 39:19 piece[1] - 38:1 piles[1] - 57:12 pinpoint[1] - 56:8 place[1] - 48:1 placed[1] - 54:8 places[1] - 25:15 plane[1] - 17:2 play[1] - 117:20 playing[1] - 58:20 pleadings[1] - 63:10 plethora[1] - 34:24 pockets[1] - 89:11 point[8] - 8:7, 42:6, 59:1, 79:6, 79:13, 89:24, 102:22, 104:4 pointed[1] - 29:13 politically[1] - 83:24 Pope[1] - 1:13 popped[1] - 16:25 poppycock[1] - 88:17 position[2] - 42:19, 116:14 possessed[2] 20:20, 21:8 possession[1] 61:24 possibility[2] - 67:6, 88:8 possible[6] - 30:23, 36:24, 37:21, 78:1, 110:1, 110:2 possibly[4] - 23:20, 42:22, 66:7, 82:15 post[1] - 37:12 post-petition[1] 37:12 potential[5] - 31:5, 37:17, 41:23, 44:18, 74:11 PowerPoint[2] 77:19, 77:21 practice[3] - 112:1, 114:5, 117:25 preceding[16] 15:13, 15:21, 19:25, 20:3, 24:3, 28:7, 32:11, 32:18, 32:22, 45:21, 45:24, 69:15, 102:24, 103:3, 103:7, 106:19 precipitated[1] 106:24 precise[1] - 35:11 preemptive[1] - 85:18 preferred[1] - 68:3 preparation[3] 62:15, 63:10, 71:8 prepare[6] - 70:21, 71:16, 73:1, 73:22, 74:2, 74:21 prepared[17] - 35:17, 67:24, 67:25, 68:1, 68:11, 69:19, 71:8, 71:23, 72:20, 72:21, 73:7, 73:12, 75:21, 95:12, 106:8 131 preparing[1] - 71:1 presence[2] - 96:2 present[1] - 36:20 presented[3] - 35:19, 42:14, 110:23 preserve[1] - 105:8 President[2] - 16:16, 16:17 press[6] - 90:2, 90:10, 91:2, 94:12, 95:12, 106:8 presumably[3] 22:15, 79:6, 95:22 presume[1] - 73:21 pretty[1] - 95:12 prevented[1] - 101:7 previous[1] - 30:7 previously[2] - 56:3, 57:2 prices[1] - 18:25 principally[1] - 89:1 PRINCIPE[165] - 2:6, 6:13, 7:12, 10:7, 11:16, 11:25, 12:4, 12:10, 12:17, 12:20, 13:16, 13:24, 14:3, 14:14, 15:3, 16:20, 17:10, 18:6, 18:11, 18:13, 18:17, 21:3, 22:21, 22:24, 23:7, 23:13, 23:18, 24:1, 24:9, 24:20, 24:25, 25:12, 25:24, 26:16, 26:18, 27:11, 28:1, 28:5, 28:15, 29:20, 32:5, 34:12, 35:21, 35:24, 36:2, 36:10, 37:7, 37:11, 38:2, 38:4, 38:13, 39:16, 39:19, 41:15, 41:20, 42:8, 43:5, 43:9, 45:10, 45:19, 45:23, 46:14, 47:10, 47:13, 48:6, 48:12, 49:3, 49:7, 49:13, 49:18, 49:22, 50:9, 50:11, 50:22, 51:3, 52:8, 52:11, 52:14, 52:17, 53:8, 54:2, 54:10, 55:6, 57:8, 57:14, 57:18, 58:6, 58:8, 58:14, 58:17, 58:24, 59:13, 60:1, 60:3, 60:19, 61:12, 61:17, 62:1, 62:5, 62:8, 62:19, 62:22, 63:13, 63:21, 64:8, 65:10, 65:14, 65:19, 65:22, 66:19, 66:25, 69:11, 70:9, 70:22, 72:7, 74:4, 74:10, 74:15, 76:3, 76:9, 84:16, 85:23, 85:25, 87:7, 90:3, 91:10, 91:13, 91:16, 91:20, 91:22, 91:24, 92:13, 93:11, 94:17, 94:23, 95:3, 97:3, 98:12, 98:14, 98:18, 98:21, 99:8, 99:13, 100:5, 100:10, 100:16, 101:9, 102:12, 102:16, 103:1, 103:6, 103:9, 104:18, 104:21, 107:17, 108:12, 108:24, 109:2, 113:2, 113:7, 113:13, 113:24, 118:15, 119:1, 119:7 Principe[3] - 50:6, 73:23, 102:22 pro[1] - 104:5 Pro[1] - 2:2 problem[6] - 39:11, 50:4, 50:13, 53:17, 57:9, 59:15 problematic[1] - 80:1 proceeding[2] 10:16, 112:22 produce[14] - 50:12, 50:13, 52:2, 52:11, 52:18, 54:5, 54:23, 54:24, 55:12, 56:17, 114:4, 115:6, 117:1, 117:25 produced[8] - 51:10, 52:2, 52:4, 53:19, 56:19, 57:1, 57:4, 112:1 producing[1] - 57:21 production[1] - 76:24 Professional[1] 1:17 profit[5] - 111:25, 112:4, 113:17, 113:23, 117:24 profit-generating[5] 111:25, 112:4, 113:17, 113:23, 117:24 program[3] - 77:20, 91:19, 116:21 prohibited[1] - 10:14 proper[1] - 29:21 proposed[1] - 83:10 proposing[1] - 83:19 proprietary[2] 81:13, 81:14 prosecute[1] - 89:23 prosecution[1] 89:20 prostitution[1] 40:11 protective[1] - 57:25 provide[5] - 9:5, 54:7, 55:16, 56:2, 112:15 provided[19] - 49:18, 53:2, 53:24, 54:2, 54:6, 54:9, 54:12, 56:3, 56:13, 58:11, 63:17, 73:6, 73:20, 76:22, 76:25, 78:12, 95:10, 104:2, 104:4 proxy[1] - 115:5 prudent[1] - 83:25 Public[4] - 1:17, 115:13, 120:13, 121:22 public[11] - 81:16, 81:20, 82:3, 85:21, 86:4, 102:6, 104:1, 104:8, 105:9, 106:6, 114:22 pull[3] - 58:17, 77:2, 78:16 pulled[1] - 100:8 purchase[1] - 75:8 purport[1] - 42:12 purporting[1] - 73:21 purpose[2] - 18:2, 94:13 PURSUANT[1] - 1:15 put[16] - 35:22, 55:14, 57:25, 58:24, 71:14, 97:21, 110:6, 111:15, 111:17, 111:18, 111:24, 113:16, 113:22, 117:23, 118:9, 118:11 putting[2] - 58:21, 92:8 Q questionable[1] 88:19 questioning[4] 22:22, 25:25, 102:13, 112:7 questions[45] - 10:12, 10:13, 10:25, 11:5, 11:8, 11:19, 12:24, 14:11, 14:12, 14:20, 18:3, 18:8, 18:20, 18:22, 18:24, 19:3, 19:4, 23:1, 23:8, 23:11, 27:18, 28:17, 28:22, 29:12, 29:15, 46:11, 46:23, 58:14, 59:10, 66:1, 66:2, 74:4, 74:15, 86:17, 97:25, 98:4, 98:10, 111:24, 112:9, 112:13, 112:14, 116:9, 118:6, 118:20, 119:11 quick[5] - 50:23, 57:10, 63:22, 72:10, 72:17 quit[1] - 98:9 quite[3] - 68:1, 80:20, 93:13 quota[1] - 117:1 quote[1] - 105:10 R raised[1] - 84:25 rarely[1] - 17:14 rather[1] - 52:3 rationale[2] - 85:3, 87:22 re[1] - 1:3 reach[1] - 93:8 reached[1] - 93:8 read[33] - 15:13, 15:19, 15:21, 19:18, 19:25, 20:3, 24:3, 28:7, 32:8, 32:11, 32:16, 32:18, 32:22, 36:7, 36:13, 45:21, 45:24, 69:11, 69:15, 72:17, 73:25, 78:14, 86:25, 87:20, 102:19, 102:24, 103:3, 103:7, 106:19, 108:21, 122:4, 122:20 real[6] - 50:22, 57:9, 63:22, 72:10, 72:16, 115:13 really[3] - 58:19, 106:15, 112:6 reason[6] - 8:15, 8:17, 24:18, 55:14, 55:21, 106:7 reasonable[2] 55:25, 56:6 reasons[3] - 22:10, 80:2, 80:5 recant[5] - 14:5, 38:24, 39:7, 40:4, 40:7 receive[1] - 48:16 recently[2] - 100:19, 100:20 Recess[4] - 15:6, 48:13, 59:8, 74:18 recognize[4] - 46:22, 73:14, 73:15, 74:2 recollection[4] 70:20, 88:7, 93:7, 111:11 record[31] - 5:18, 14:15, 15:4, 24:21, 33:13, 36:22, 48:12, 50:22, 50:24, 51:1, 51:2, 51:3, 51:23, 57:9, 57:10, 57:11, 59:5, 59:17, 63:22, 63:23, 63:24, 78:15, 81:20, 88:4, 96:24, 102:5, 118:10, 118:11, 119:20, 119:21, 121:7 Records[1] - 115:13 records[14] - 56:7, 56:9, 57:4, 72:24, 77:6, 78:3, 81:17, 82:3, 85:21, 86:4, 102:6, 104:1, 104:8, 114:22 refer[3] - 85:8, 86:17, 104:19 reference[2] - 27:5, 77:17 referred[7] - 61:6, 85:7, 96:17, 110:3, 110:17, 110:19, 115:11 referring[2] - 41:18, 63:17 reformat[2] - 56:1, 58:23 refresh[5] - 35:9, 47:17, 71:13, 71:18, 74:19 refreshing[1] - 71:24 refuse[1] - 18:15 refused[4] - 8:9, 8:13, 81:12, 96:12 refusing[3] - 10:23, 14:17, 14:22 regarded[2] - 82:2, 84:5 regarding[2] - 14:21, 71:21 regularly[2] - 85:21, 86:6 reimbursed[1] - 51:21 relate[4] - 11:20, 12:6, 14:9, 25:25 related[2] - 10:17, 11:1 relates[6] - 10:8, 12:5, 12:8, 27:16, 71:2, 71:5 relating[4] - 71:9, 99:2, 112:15, 112:16 relationship[4] 90:13, 96:24, 101:6, 102:10 relative[2] - 121:8, 121:10 132 release[3] - 94:12, 95:12, 106:9 relevant[12] - 11:12, 18:7, 24:25, 74:6, 74:7, 74:8, 74:9, 74:10, 76:4, 93:11, 93:13 rely[4] - 110:9, 110:12, 110:13, 110:14 remember[26] - 8:3, 19:24, 34:1, 34:4, 34:9, 34:11, 34:25, 46:24, 47:2, 47:3, 55:10, 58:1, 69:22, 75:10, 82:21, 88:5, 96:1, 99:14, 99:15, 99:16, 101:3, 104:14, 107:6, 107:7, 107:10 remind[1] - 37:7 remote[1] - 112:18 repeat[2] - 79:10, 105:1 repeatedly[6] - 95:21, 96:12, 97:21, 106:14, 115:21, 117:5 repetitive[1] - 75:13 rephrase[3] - 16:1, 16:9, 16:22 report[1] - 121:5 REPORTED[1] - 1:16 REPORTER[20] - 5:1, 5:5, 19:19, 32:10, 48:14, 51:24, 59:18, 69:14, 79:9, 79:13, 83:12, 83:14, 86:3, 102:20, 105:1, 106:17, 107:14, 107:20, 109:8, 121:1 Reporter[2] - 1:17, 3:8 reporter[18] - 15:14, 15:22, 20:1, 20:4, 24:4, 28:8, 32:12, 32:19, 32:23, 45:22, 45:25, 69:16, 97:13, 98:19, 102:25, 103:4, 103:8, 106:20 reporter's[5] - 26:12, 26:23, 27:3, 27:4, 29:15 reporters[1] - 94:11 reports[1] - 52:5 represent[3] - 82:5, 84:6, 104:7 represented[3] - 48:3, 90:5, 90:20 representing[5] 27:16, 58:1, 90:9, 91:1, 106:25 request[10] - 58:3, 58:7, 63:13, 75:25, 76:23, 78:5, 81:17, 81:21 requested[6] - 9:3, 51:17, 56:8, 61:12, 61:13, 81:9 required[1] - 122:6 requirement[1] 83:23 reread[2] - 61:14, 61:16 resend[2] - 95:24, 106:14 resign[2] - 95:10, 106:8 resignation[3] 106:7, 106:22, 106:23 resigned[2] - 67:16, 95:18 resources[1] - 89:19 respect[1] - 80:7 response[6] - 20:2, 23:3, 42:17, 56:12, 106:3, 112:13 responsibilities[1] 67:10 responsive[1] - 78:4 result[1] - 40:13 retract[3] - 95:23, 96:13, 106:14 returns[2] - 58:11, 58:18 revenue[1] - 115:16 revenue-generating [1] - 115:16 review[2] - 61:3, 117:7 review-generating[1] - 117:7 reviewed[1] - 46:6 RICO[7] - 89:9, 89:20, 101:15, 101:16, 101:17, 101:18, 101:21 rights[1] - 114:21 Rights[1] - 88:13 RING[1] - 83:16 Ring[11] - 75:24, 79:2, 79:4, 80:16, 83:10, 83:16, 90:4, 91:18, 95:20, 104:3, 115:25 road[2] - 17:8, 17:16 roads[2] - 17:19, 17:21 Robert[4] - 9:18, 9:20, 85:13, 85:15 room[2] - 38:23, 89:12 round[1] - 8:25 rudely[1] - 102:22 Rule[1] - 48:17 Ruppel[1] - 1:13 Russell[1] - 79:3 Ryan[10] - 100:24, 101:7, 102:4, 102:9, 103:16, 103:19, 103:23, 104:2, 104:3, 104:4 S sadly[2] - 112:3, 114:19 sake[1] - 83:25 Samuel[2] - 44:17, 44:18 sarcasm[1] - 25:13 satisfied[1] - 68:2 save[2] - 98:7, 98:9 saw[1] - 33:11 schedule[3] - 30:6, 44:21, 59:22 schedules[9] - 23:12, 23:14, 23:17, 23:18, 31:5, 36:9, 36:13, 38:5, 64:1 scheme[7] - 111:25, 112:4, 113:17, 113:23, 115:16, 117:7, 117:24 scope[1] - 63:11 screen[2] - 58:22, 58:24 scriveners[1] - 110:3 se[2] - 2:2, 104:5 seal[1] - 120:7 search[3] - 77:9, 77:11, 78:22 searching[1] - 78:22 second[5] - 38:15, 48:12, 63:12, 75:10, 119:20 see[26] - 10:2, 13:6, 15:3, 18:17, 22:8, 22:12, 22:13, 22:21, 33:11, 33:14, 33:20, 44:16, 50:25, 51:5, 59:23, 60:24, 75:15, 75:17, 75:18, 75:19, 84:8, 89:15, 93:24, 98:12, 115:9 seeks[1] - 105:6 self[4] - 80:7, 85:5, 87:24, 88:9 self-dealing[4] - 80:7, 85:5, 87:24, 88:9 sellers[2] - 80:22, 81:9 send[1] - 8:22 Senior[1] - 5:14 senior[3] - 82:1, 82:11, 85:20 sense[5] - 89:21, 96:19, 96:20, 96:21 sent[6] - 8:9, 8:19, 68:8, 89:4, 95:5 sentence[2] - 87:21, 92:8 separated[1] - 95:13 seriously[1] - 97:17 service[1] - 49:7 set[1] - 80:23 settlement[3] - 13:24, 14:1, 115:17 several[5] - 19:7, 61:6, 67:8, 68:13, 83:8 shaking[1] - 101:14 shame[1] - 80:20 share[1] - 92:2 shared[1] - 92:5 sharing[1] - 10:19 SHEET[1] - 122:1 sheet[1] - 75:11 sheets[1] - 36:14 Sherry[3] - 47:21, 47:24, 48:3 shoes[1] - 81:4 short[1] - 113:19 show[6] - 50:15, 50:16, 50:20, 60:15, 70:3, 74:25 showing[1] - 34:24 Shula's[1] - 105:20 sides[1] - 82:2 sign[1] - 122:6 Signature[1] - 3:9 SIGNATURE[1] 122:1 signature[3] - 64:16, 64:25, 122:23 signed[4] - 64:2, 64:3, 64:13, 65:5 similar[3] - 29:16, 81:20, 81:21 simple[1] - 13:19 simply[3] - 111:24, 113:16, 117:23 Simply[1] - 113:22 single[2] - 75:16, 75:17 sit[2] - 31:19, 79:25 sitting[2] - 105:17, 105:20 six[4] - 99:5, 99:21, 100:5, 100:21 slander[10] - 31:6, 31:11, 31:12, 33:20, 38:4, 38:8, 41:23, 42:9, 43:1, 43:8 slanders[1] - 34:24 slow[2] - 85:23, 109:8 smartass[1] - 17:1 sole[1] - 13:2 solicitation[1] - 40:11 solitary[1] - 63:8 someone[4] - 84:3, 86:18, 96:3, 96:17 someplace[1] - 33:19 sometimes[1] - 71:14 somewhat[1] 111:10 somewhere[1] 24:10 son[7] - 41:14, 41:19, 44:16, 96:25, 97:15, 98:25, 99:7 son's[7] - 80:5, 99:21, 112:1, 114:5, 114:24, 115:1, 117:25 sons[1] - 44:15 sorry[34] - 7:18, 9:19, 10:4, 21:24, 31:8, 31:25, 39:25, 47:6, 53:13, 53:16, 53:18, 59:2, 64:18, 64:19, 65:8, 78:10, 78:16, 78:18, 79:9, 79:11, 83:12, 83:13, 85:24, 90:16, 95:1, 102:7, 104:16, 105:1, 105:3, 106:17, 106:18, 108:14, 109:8, 109:10 sort[2] - 23:3, 83:1 sought[1] - 46:6 sound[1] - 104:17 sounded[1] - 17:1 south[1] - 67:4 southern[2] - 20:10, 20:12 speaking[3] - 62:2, 76:17, 79:4 specific[3] - 65:15, 65:19, 102:16 specifically[1] - 54:10 speculate[1] - 5:25 speculating[1] 100:11 speeches[1] - 113:20 spend[3] - 39:8, 40:6, 89:21 spite[1] - 115:3 spoken[1] - 9:23 St[1] - 48:4 stalk[1] - 14:7 stamp[1] - 78:24 stand[2] - 81:4, 114:8 standing[3] - 27:17, 86:21, 87:3 133 start[3] - 42:7, 74:14, 77:11 started[2] - 104:6, 106:13 state[3] - 5:17, 7:18, 85:19 State[3] - 1:18, 120:14, 121:23 STATE[2] - 120:2, 121:2 STATED[1] - 1:1 statement[25] - 29:5, 29:8, 33:4, 33:6, 33:12, 55:20, 64:23, 65:2, 65:4, 69:12, 70:4, 92:10, 98:6, 104:11, 108:7, 108:10, 108:19, 109:20, 109:24, 110:9, 111:19, 112:11, 114:11, 115:15, 117:6 statements[11] 31:13, 31:15, 32:25, 68:13, 97:25, 98:1, 98:3, 98:10, 102:14, 118:19, 118:22 States[4] - 30:5, 53:25, 54:13, 56:13 status[4] - 6:22, 7:6, 7:7, 7:11 stay[3] - 57:11, 88:18, 89:24 stayed[1] - 112:20 steakhouse[1] 105:20 stenographically[1] 121:5 step[1] - 50:17 stew[1] - 18:4 stick[1] - 11:21 still[8] - 22:21, 51:20, 84:16, 89:21, 89:22, 106:4, 115:23, 116:1 stole[1] - 33:2 stop[4] - 13:5, 15:24, 74:14, 102:23 stopping[1] - 118:13 store[2] - 25:10, 81:2 stores[1] - 25:23 Street[2] - 1:13, 5:19 streets[1] - 25:19 strike[2] - 20:18, 67:19 strongly[1] - 41:17 structure[1] - 30:24 stuff[2] - 41:6, 41:7 subject[3] - 57:21, 62:16, 62:21 submitted[2] - 8:8, 9:2 subpoena[3] - 49:12, 49:13, 52:24 subscribe[1] - 122:20 subsequent[1] 71:25 sue[1] - 42:16 sued[5] - 80:22, 81:10, 86:12, 90:2, 107:1 suggestion[1] - 80:9 suggestions[1] - 85:6 suing[1] - 112:19 suit[4] - 27:13, 101:15, 101:17, 101:18 suite[1] - 1:14 Suite[2] - 2:7, 2:10 suits[2] - 101:16, 104:1 summary[2] - 36:13, 64:1 summon[1] - 20:12 summoned[1] - 20:9 sundry[1] - 19:9 supplied[2] - 102:11, 103:13 support[1] - 118:1 suppose[2] - 18:23, 109:25 supposed[5] - 45:16, 52:2, 56:17, 68:14, 70:1 surprised[1] - 26:23 suspect[1] - 86:9 swear[1] - 5:1 sweet[1] - 101:4 Sweet[1] - 23:16 Sweetapple[33] 9:18, 9:20, 11:9, 12:8, 12:13, 15:25, 16:4, 16:19, 17:20, 17:24, 20:22, 22:5, 23:16, 26:15, 26:21, 27:5, 29:4, 29:17, 71:9, 71:17, 72:20, 74:9, 77:18, 77:22, 77:23, 78:3, 93:4, 93:7, 106:24, 107:5, 107:8, 108:8 sworn[13] - 5:7, 14:5, 29:4, 29:8, 38:24, 39:7, 40:4, 40:7, 108:7, 109:24, 111:19, 114:11, 120:6 T T-W-E-E-L[1] - 79:17 table[2] - 11:6, 27:25 TAMPA[1] - 1:2 Tampa[3] - 1:14, 2:7, 86:11 taste[1] - 55:18 tax[5] - 58:11, 58:17, 86:24, 87:11, 88:22 taxpayers[1] - 89:18 Taylor[7] - 95:25, 96:1, 96:3, 96:10, 96:14, 106:21, 115:19 teachers[1] - 92:15 technical[1] - 89:1 telephone[2] 106:10, 116:2 templates[5] 102:11, 103:13, 103:23, 103:25, 104:1 temporary[1] - 8:1 tenure[1] - 76:11 terabyte[1] - 51:6 terabytes[2] - 51:7 Teresa[1] - 41:7 term[1] - 99:6 terms[1] - 86:8 testified[1] - 5:8 testify[2] - 21:24, 97:17 testifying[4] - 37:13, 53:22, 97:20, 98:22 TESTIMONY[1] - 3:2 testimony[7] - 5:2, 14:5, 38:25, 39:7, 40:5, 40:7, 121:7 that'll[1] - 18:16 THE[57] - 5:1, 5:4, 5:5, 13:19, 14:1, 14:4, 18:19, 19:19, 19:21, 20:16, 25:2, 32:10, 45:14, 46:1, 48:14, 50:24, 51:12, 51:16, 51:24, 58:13, 58:19, 58:25, 59:18, 62:10, 62:14, 69:14, 72:4, 79:9, 79:11, 79:13, 79:15, 83:12, 83:13, 83:14, 83:16, 84:18, 85:24, 86:1, 86:3, 86:5, 97:5, 102:20, 105:1, 105:3, 106:17, 106:18, 107:14, 107:20, 109:8, 109:10, 113:8, 117:22, 118:18, 119:5, 119:9, 119:14, 119:17 themselves[2] 35:19, 36:20 they've[1] - 11:10 Third[2] - 86:13, 86:14 Thomas[17] - 47:5, 75:25, 80:24, 81:24, 82:1, 82:2, 82:5, 84:4, 84:9, 84:11, 85:11, 85:19, 90:10, 90:18, 90:21, 92:19, 92:20 Thomas'[1] - 105:7 thousands[15] 52:20, 52:21, 52:25, 53:1, 53:9, 53:10 threat[1] - 14:2 threaten[4] - 39:23, 39:24, 40:1, 96:16 threatened[9] - 13:21, 38:23, 38:24, 39:6, 39:7, 39:23, 40:3, 95:6, 106:10 three[3] - 34:8, 83:19, 100:3 thrust[1] - 21:16 Thursday[1] - 106:22 ties[1] - 23:16 TIME[1] - 1:12 time-out[1] - 119:19 timeline[21] - 70:21, 71:8, 71:21, 71:23, 71:24, 72:22, 73:1, 73:6, 73:12, 73:22, 74:1, 76:13, 78:17, 104:12, 108:2, 108:20, 110:9, 110:14, 110:16, 110:17, 110:20 timelines[2] - 71:1, 71:12 tires[5] - 19:1, 19:10, 19:11, 19:17, 19:24 TLO[2] - 85:11 TLo[8] - 85:16, 85:18, 86:10, 86:15, 86:20, 90:25, 91:1 TO[2] - 1:15, 122:3 today[17] - 36:1, 36:2, 37:9, 44:5, 47:12, 47:19, 48:19, 48:20, 48:22, 49:1, 49:2, 52:8, 59:11, 61:6, 76:25, 96:21, 112:9 together[2] - 51:19, 83:18 tomorrow[11] - 61:9, 61:22, 118:25, 119:2, 119:8, 119:9, 119:10, 119:15, 119:18 tone[1] - 95:12 tonight[1] - 117:21 took[1] - 29:4 top[9] - 31:18, 33:9, 34:4, 36:20, 54:4, 55:9, 69:21, 99:3, 115:10 topics[1] - 19:8 total[2] - 41:2, 75:13 towards[2] - 22:22, 82:4 town[4] - 89:19, 101:6, 105:23, 105:24 Town[1] - 101:18 transcribe[1] - 85:25 transcript[8] - 107:5, 109:19, 110:13, 111:7, 121:6, 122:4, 122:5, 122:20 transcription[1] 122:5 transcriptionist[1] 20:7 transportation[1] 16:13 transportation-wise [1] - 16:13 trash[3] - 99:9, 99:10, 99:15 trashed[3] - 97:15, 99:6 travel[1] - 17:18 traveling[2] - 17:18, 22:15 tree[1] - 24:11 tried[1] - 117:15 trip[1] - 21:21 troubling[1] - 111:10 true[30] - 36:14, 40:16, 55:20, 64:2, 64:3, 64:14, 64:15, 64:21, 64:24, 65:1, 68:24, 70:4, 73:2, 108:6, 108:18, 108:19, 109:15, 109:16, 109:18, 109:19, 110:4, 110:12, 111:8, 111:16, 111:18, 111:20, 111:21, 121:6 trumped[1] - 88:16 trustee[13] - 42:15, 42:22, 53:25, 54:3, 54:13, 55:11, 56:13, 56:14, 56:15, 56:18, 58:11 truth[6] - 5:2, 5:3, 37:1, 39:11, 60:14 truthful[3] - 39:13, 39:14, 39:15 truthfulness[1] 112:10 try[12] - 28:24, 55:24, 134 56:6, 56:21, 57:1, 57:2, 57:4, 58:3, 66:18, 89:24, 103:21, 112:23 trying[8] - 42:13, 42:21, 66:2, 85:25, 88:17, 89:5, 89:23, 92:25 turn[1] - 11:7 turnpike[3] - 17:4, 17:5, 17:17 Tweel[10] - 79:4, 79:17, 82:11, 82:19, 82:24, 83:4, 85:2, 86:23, 87:5, 87:11 twice[1] - 30:4 two[10] - 9:16, 31:8, 44:1, 59:5, 65:20, 83:10, 83:17, 83:19, 108:11, 116:17 two-part[1] - 31:8 type[3] - 18:24, 52:4, 58:14 typo[1] - 85:7 U ultimate[2] - 114:18, 115:14 ultimately[2] - 68:10, 114:23 unable[1] - 55:21 unanimous[1] - 46:7 unclear[1] - 111:10 under[25] - 5:7, 5:25, 21:25, 23:19, 29:12, 33:13, 35:10, 36:12, 45:3, 46:10, 64:2, 64:13, 77:23, 84:16, 97:4, 97:18, 97:21, 97:22, 99:16, 109:20, 111:11, 111:18, 111:19, 118:23 undersigned[1] 120:4 undiplomatic[1] 116:3 unfair[1] - 112:21 unfolded[1] - 71:25 unfortunately[1] 13:2 UNITED[1] - 1:1 United[4] - 30:5, 53:25, 54:13, 56:13 university[3] - 81:4, 81:7, 81:15 unknowingly[1] 101:5 unknown[2] - 36:23, 37:22 unleash[1] - 14:6 unless[4] - 8:5, 50:4, 63:7, 95:4 unlimited[1] - 89:18 unpleasantness[2] 95:22, 96:15 unquote[1] - 105:11 unresolved[1] - 95:14 unsatisfactory[1] 34:23 unsavory[1] - 88:18 unsecured[2] - 59:24 up[13] - 26:22, 27:2, 28:21, 29:7, 29:14, 53:6, 53:8, 58:17, 77:2, 81:12, 85:3, 88:16, 89:9 upcoming[1] - 81:8 updated[2] - 9:5, 104:9 upward[1] - 92:10 USF[3] - 81:2, 81:17, 85:13 utterances[1] 111:20 uttered[2] - 70:11, 111:12 uttering[1] - 70:7 V validations[1] 115:14 VANESSA[3] 120:13, 121:4, 121:22 vANESSA[1] - 1:16 various[2] - 19:8, 99:1 vehicle[1] - 81:19 veracity[1] - 110:23 verb[1] - 110:1 verbally[2] - 88:11, 95:11 verbatim[2] - 75:22, 109:5 verify[2] - 73:2, 73:3 version[1] - 68:9 versions[1] - 68:9 versus[1] - 85:12 vexatious[1] - 44:20 videotaped[3] - 2:5, 33:11, 33:14 VIDEOTAPED[1] - 1:9 viewed[1] - 77:20 violation[1] - 89:1 violations[1] - 115:13 Virginia[1] - 82:12 virtually[2] - 86:12, 89:18 visit[1] - 81:22 visited[2] - 81:2, 85:13 visualize[1] - 71:15 vociferous[1] 116:13 voice[1] - 92:11 voluminous[1] - 56:8 vouch[2] - 72:22, 73:20 vulgar[1] - 116:4 W wait[1] - 75:9 wants[4] - 13:17, 14:12, 51:18, 52:16 warning[3] - 88:12, 95:10, 95:11 wasted[1] - 59:11 wealthy[2] - 39:8, 40:5 Web[1] - 87:14 website[9] - 98:25, 99:3, 99:6, 99:22, 100:8, 100:13, 100:15, 100:18, 100:19 Wednesday[1] - 79:6 Weds[1] - 79:5 week[4] - 29:14, 79:5, 115:7, 117:2 welcome[1] - 97:23 well-known[1] - 84:5 West[3] - 2:3, 2:7, 82:12 Westshore[1] 105:19 wherein[1] - 99:21 white[2] - 55:18, 55:19 whitepeachestasteg ood[1] - 55:17 whole[4] - 5:2, 14:13, 102:2, 111:20 wife[2] - 30:13, 39:3 William[1] - 79:4 willing[3] - 16:8, 82:5, 84:6 willingness[1] - 36:25 wise[1] - 16:13 withdraw[3] - 96:9, 96:13, 96:16 Witmer[3] - 100:24, 101:7, 102:4 WITNESS[4] - 5:4, 120:7, 122:2, 122:3 Witness[1] - 101:14 witness[3] - 5:7, 121:7, 122:23 135 woman[1] - 48:2 word[4] - 55:17, 72:17, 75:5, 99:14 words[14] - 70:7, 70:8, 70:12, 70:14, 70:15, 70:16, 70:18, 77:22, 82:23, 99:17, 103:14, 105:16, 111:12 works[3] - 50:16, 70:25, 97:24 world[5] - 24:18, 53:20, 74:13, 91:9, 94:3 worried[3] - 87:1, 87:17, 87:19 wreck[1] - 39:9 writing[3] - 68:13, 88:11, 115:6 written[4] - 85:22, 86:6, 88:12, 95:10 wrote[2] - 62:15, 84:25 Y year[6] - 9:14, 44:11, 76:9, 76:23, 82:13, 88:4 years[13] - 5:24, 6:2, 6:5, 6:11, 6:15, 6:16, 6:17, 6:25, 9:16, 82:12, 86:14, 88:14 yes-or-no[1] - 35:15 YMCA[1] - 25:21 you-all[1] - 56:20 young[1] - 32:9 yourself[3] - 36:16, 89:7, 118:12 YouTube[4] - 33:16, 33:17, 33:18, 41:25 .pdf 100120~1.pdf 10.01.2015 - In re Chandler.pdf application/pdf 6771C68E36EAB24B967EB868AE282C84@gulf-stream.org EnUs 10.1.2015 - In re Chandler - Exhibit 01.pdf .pdf 101201~1.pdf 10.1.2015 - In re Chandler - Exhibit 01.pdf application/pdf D7F82AE29812ED40A8D87D5A510BBD06@gulf-stream.org EnUs 10.1.2015 - In re Chandler - Exhibit 02.pdf .pdf 101201~1.pdf 10.1.2015 - In re Chandler - Exhibit 02.pdf application/pdf 9331823A190F6646B508939217A14096@gulf-stream.org EnUs 10.1.2015 - In re Chandler - Exhibit 03.pdf .pdf 101201~1.pdf 10.1.2015 - In re Chandler - Exhibit 03.pdf application/pdf 38F2225AB28F2F4EA773E6FD2B6C57F1@gulf-stream.org EnUs 10.1.2015 - In re Chandler - Exhibit 04.pdf .pdf 101201~1.pdf 10.1.2015 - In re Chandler - Exhibit 04.pdf application/pdf B98BA1C9921824438E23BD57523E0CA4@gulf-stream.org EnUs 10.1.2015 - In re Chandler - Exhibit 05.pdf .pdf 101201~1.pdf 10.1.2015 - In re Chandler - Exhibit 05.pdf application/pdf 2DB61552B7D04E48A6C42ED78F8BBF16@gulf-stream.org EnUs 10.1.2015 - In re Joel Chandler - Certificate Pages 120 & 121.pdf .pdf 101201~1.pdf 10.1.2015 - In re Joel Chandler - Certificate Pages 120 & 121.pdf application/pdf 8562220DF86E404FBB17F94DD9D58C2C@gulf-stream.org EnUs