HomeMy Public PortalAboutShelly O'Hare Deposition Transcripts 12/19/14In The Matter Of:
CHRISTOPHER F. O'HARE v.
TOWN OF GULF STREAM
Deposition ofSHELLEYO'HARE
December 19, 2014
DEBRA DURAN
A S S O C I A T E S
Registered Professional Reporters
P.O. Box 2288
West Palm Beach, Florida 33402
561- 313 -8000
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IN THE CIRCUIT COURT OF THE
15TH JUDICIAL CIRCUIT IN AND FOR
PALM BEACH COUNTY, FLORIDA
Case No.: 50 2013 CA 017717
XXXX MB
CHRISTOPHER F. O'HARE,
Plaintiff,
Vs.
TOWN OF GULF STREAM,
Defendant
VIDEOTAPED DEPOSITION OF
SHELLEY CHILDERS O'HARE
DATE TAKEN: December 19, 2014
TIME: 2:49 p.m. - 5:28 p.m.
PLACE: Debra Duran & Associates
5550 Glades Road
Boca Raton, Florida
Examination of the witness before:
Mia Sohn, RPR
Certified Shorthand Reporter
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ON BEHALF OF THE PLAINTIFF:
LAW OFFICES OF GMM I MADISON, P.A.
BY: MARK J. HANNA, ESQUIRE
401 South County Road, #3272
Palm Beach, Florida 33480
(561)223 -9990
mhanna@g3mlaw.com
ALSO PRESENT:
Christopher O'Hare
LAW OFFICES OF LOUIS ROEDER, III
BY: LOUIS ROEDER, III, ESQUIRE
7414 Sparkling Lake Road
Orlando, Florida 32819
(407)352 -4194
louolouroeder.com
LAW OFFICES OF SWEETAPPLE, BROEKER & VARKAS,
P.L.
BY: ROBERT A. SWEETAPPLE, ESQUIRE
20 S.E. Third Street
Boca Raton, Florida 33432
(561)392 -1230
pleadings@sweetapplelaw.com
LAW OFFICES OF JONES, FOSTER, JOHNSTON &
STUBBS, P.A.
BY: JOANNE M. O'CONNOR, ESQUIRE
505 South Flagler Drive, Suite 1100
West Palm Beach, Florida 33402
(561)659 -3000
joconnorojonesfoster.com
ALSO PRESENT:
Bo Cooper, Videographer
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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I N D E X
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WITNESS: SHELLEY CHILDERS O'HARE
PAGE
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Direct Examination by Mr. Sweetapple
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Cross Examination by Mr. Hanna
144
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- - - - - - -
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E X H I B I T S
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FOR DEFENDANT
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NO. DESCRIPTION
PAGE
12
1 1998 calendar, 12 pages
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2 1999 calendar, 9 pages
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3 Code enforcement stipulation and order,
9 pages
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4 4/7/98 letter to Mr. Nicoletti from
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Mr. Jonas
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5 Public records request log, 46 pages
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Debra Duran & Associates
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1 Thereupon, the following proceedings were had:
2 VIDEOGRAPHER: It is the 19th day of
3 December, 2014. The time is 2:49 p.m. This
4 will be the videotaped deposition of Shelley
5 Childers O'Hare in the matter of Christopher
6 O'Hare versus Town of Gulf Stream.
7 This deposition is being held at 20 S.E.
8 Third Street, Boca Raton, Florida -- oh, I'm
9 sorry, 5500 Boca Raton, Florida, 33432.
10 My name is Bo Cooper and I'm the
11 videographer with Legal Graphicworks.
12 At this time, will the attorneys please
13 announce their appearances for the record?
14 MR. SWEETAPPLE: Plaintiff?
15 MR. HANNA: Mark Hanna for Christopher
16 O'Hare.
17 MR. SWEETAPPLE: Robert Sweetapple,
18 Sweetapple, Broeker & Vargas, and Joanne
19 O'Connor, Jones & Foster, on behalf of the
20 Town of Gulf Stream.
21 MR. ROEDER: And Lou Roeder for Shelley
22 O'Hare.
23 - - - - - - -
24 Thereupon,
25 SHELLEY CHILDERS O'HARE,
Debra Duran & Associates
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was called as a witness and, after having been
first duly sworn, was examined and testified as
follows:
DIRECT EXAMINATION
BY MR. SWEETAPPLE:
Q. Good afternoon. How are you?
A. I've been better.
Q. Okay. I'm sorry to hear that.
My name is Bob Sweetapple. I represent
the Town of Gulf Stream in one of many cases that
your husband has instituted against the Town.
I believe you received a subpoena in
this case, have you not --
A. Yes.
Q. -- for a deposition here today?
Did you have a chance to read the
request in Exhibit A for documents?
A. No.
Q. When you got the subpoena, did you
notice that it said any and all documents that
refer to any representation of you or your husband,
Christopher O'Hare, by Robert A. Sweetapple,
Esquire or Sweetapple, Broeker & Vargas, P.L. from
1997 through 1999? Did you notice that on the
subpoena when you got it?
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A. No.
Q. Okay. You did bring or at least your
attorney as I came in handed me some documents to
review, which he represented are excerpts from your
calendars for 1998 and 1999; is that correct?
A. I don't know what they handed you. I
assume that's what they handed you.
Q. Well, take a look. That's a copy of
what they handed me, which I'm going to mark as
Exhibits 1 and 2 to your deposition.
A. Yes.
(The documents referred to were
subsequently marked Defendant's Exhibit
Nos. 1 and 2 for identification, copies
of which are attached hereto.)
BY MR. SWEETAPPLE:
Q. Did you locate those documents?
A. No, I did not.
Q. Who located those documents?
A. My husband.
Q. Is it fair for me to conclude that
because you did not see Exhibit A to the subpoena,
that you did not yourself look for documents?
A. I did not look for documents.
Q. Okay. And so you don't know if you have
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any records or documents that refer to any
representation of your husband or yourself by me or
my law firm in the late 190s?
A. What is your question?
Q. As you sit here today, are you able to
tell me without having looked whether or not --
other than the documents that are in front of you,
the two calendar excerpts from 198 and 199, are you
able to tell me if you have any other documents
that concern representation by me or my firm of you
or your husband during 1998 or 1999?
A. My husband dealt with you then. We
hired you. We confided in you. We paid you. You
did a good job for us. You were our advocate.
■gym■
Q.
Well,
I'm
asking --
A.
-- I
don't
have any documents. Chris
dealt with that.
Q. So you have not looked for documents,
but you know you don't have any documents?
A. I don't have documents. I have not
looked for documents that I don't have.
Q. So you know sitting here that you have
no records of cancelled checks for having paid me a
fee?
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A. To my knowledge, I would have no
cancelled checks from the 1990s, correct.
Q. Do you have any fee agreements?
A. Any what?
Q. Fee agreements, copies of any retainer
agreements.
A. To my knowledge, I have no fee
agreements.
Q. Did you ever see a fee agreement with my
law firm?
A. To my knowledge, I have no fee
agreements. I do not remember.
Q. So you don't remember if you've ever
seen one?
A. I don't know.
Q. Do you know if you ever wrote a check to
my law firm?
A. I don't know.
Q. Did you ever write a check to my law
firm?
A. I don't recall.
Q. Have you ever been to my law office?
A. Not that I recall.
Q. Have you ever met me before today?
A. Yes, I have.
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Q.
When did you meet me?
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A.
I believe we met at the Town of Ocean
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Ridge.
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Q.
You're believing or you recall
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specifically?
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A.
I'm not sure if it was there or before,
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but we've
met before.
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Q.
Today I'm going to ask you a series of
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questions
that you're answering under oath and
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they're to be answered based on your personal
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knowledge,
not on any guessing or speculating.
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Is that clear? Do you understand that?
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A.
I understand that.
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Q.
Okay. Can you definitely testify under
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oath that
you have met me in the past?
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A.
I have seen your face before. I have
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met you face to face before somewhere. Whether it
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was in relation
to that case, I don't know, but we
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have met.
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Q.
Okay. And tell me under oath when you
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specifically recall having met me before.
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A.
I don't specifically recall the
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instance.
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Q.
So you met me you believe on one
25 occasion, but you don't know where it was?
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A. I don't remember.
Q. You don't know if it was a party, a
meeting, a social event, correct?
A. I don't remember.
Q. Do you remember where it was?
A. I don't remember.
Q. Okay. Do you have any recollection of
ever having been in my law office?
A. Not that I recall. I do not remember
going to your law office. Chris dealt with you at
that time.
Q. Do you recall ever --
And you would only know that by talking
to Chris, right, because you weren't present?
A. What is the question?
Q. You said Chris dealt with me at that
time.
When you say that, you're referring to
what time period?
A. When we were being represented by you.
Q. Okay. You were represented by me, also?
A. When we had a contract with you, when we
confided in you, when you acted as our attorney,
all of those times.
Q. In terms of the contract, was there a
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contract with me or my firm where you were a
client?
A. I don't remember.
Q. Well, why did you say when we had a
contract with you? Who were you referring to as
we?
A. I've been married to Chris for 31 years.
I consider us a pretty strong team.
Q. And was there ever a contract for
representation where your name was named as a
client?
A. I don't remember.
Q. And in terms of confided, did you ever
meet with me and confide anything to me?
A. I don't remember.
Q. And you say I acted as your attorney.
Where did I act as your attorney?
A. Chris and I had legal issues in the Town
of Ocean Ridge. We were married at the time. We
owned property together.
Q. So Chris and you had legal issues --
A. You represented -- I don't know if it
was Chris or us, but you represented my husband and
me for that property.
Q. You're talking about an apartment
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building in Ocean Ridge?
A. Yes.
Q. Okay. And was that a -- was that a code
enforcement issue?
A. I don't remember.
Q. Do you remember anything about -- do you
have any specific knowledge of any legal work I've
ever done for you, for you personally, whether
individually or with your husband or in any entity
that you are affiliated with?
A. Say that question again.
Q. As you sit here today, are you aware of
any specific matter that you state I represented
you in?
A. You represented us --
Q. I'm just asking about you now, just you.
I want to know about you. We'll talk about your
husband next. Just you.
A. I was a partner in owning the apartment
building, so I would consider that if you're
representing us in a legal issue with the apartment
building, that you would be representing me.
Q. Okay. Now, did you own the apartment
building or did an entity own the apartment
building?
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A. We bought it together. I think during
the period we owned it, we converted it to an LLC.
Q. And in 1998, it was owned by an LLC,
right?
A. I don't remember.
Q. In fact, at the time of the code
enforcement issue, it was owned by an, LLC,
correct?
A. I don't remember.
Q. And were you a member of any LLCs in
i�lIiU
A. I just told you I don't know if it was
owned in 1998 by an LLC. I cannot answer that
question.
Q. If the question's read back to you,
you'll know that the question was were you a member
of any LLCs in 1998?
A. I don't remember.
Q. Okay. So you believe that my firm
represented you with regard to a code enforcement
violation regarding an apartment building in
Ocean Ridge in 1998?
A. What is the question?
Q. The question is a leading question.
Is it a fact that you believe that my
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firm represented you in a code enforcement matter
with the Town --
A. I don't know what the issue was, but you
represented us. You had conversations with Chris.
He confided in you. I can remember him giving me
occasional updates, "Oh, Sweetapple said to do
this," or, you know, "I talked to Sweetapple about
this," you know --
Q. Everything you're telling me about my
representation came from what your husband said?
A. Correct.
Q. I notice that you're here telling me
about conversations with your husband.
Is it your intention to waive the
husband /wife privilege with regard to your
communications with your husband or are you going
to --
Are you aware that there's a
husband /wife --
A. I don't know what that means.
Q. Okay. In the state of Florida, there is
a privilege that a husband or a wife do not have to
divulge their communications.
It sounds to me based on your answers at
this point that you have a strong belief that I
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contracted with your husband, that your husband
confided in me and that I acted as your husband's
attorney, but each time you've discussed that
matter, you've referred specifically to statements
your husband's made.
Are you waiving the husband /wife
privilege or are you here to tell me what your
husband told you with regard to the representation?
A. I would have to talk to my attorneys
about that.
Q. Okay. Let's take a break, because you
yourself in your attorney's presence I believe have
waived the husband /wife privilege arguably, but I
don't want to put you in a position where you've
waived that privilege --
A. You're not my attorney, right, so --
Q. I'm not your attorney. I don't want to
put you in a position where you act to waive the
privilege until you've had a chance to talk to
Mr. Roeder. So why don't we take a break.
VIDEOGRAPHER: The time is 3:01. We're
going off --
THE WITNESS: Could I ask you to leave
the room while they confer with me?
I wear hearing aids. I need to be able
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to understand them.
MR. SWEETAPPLE: I was going to let you
two leave the room if you didn't mind,
because there's six of us, and you don't want
any of us present when you're having a
confidential communication with your lawyer.
THE WITNESS: All right. That's a fair
assessment.
VIDEOGRAPHER: The time is 3:02. We're
going off record.
(Recess from 3:02 p.m. to 3:06 p.m.)
VIDEOGRAPHER: The time is 3:06. We're
back on record.
BY MR. SWEETAPPLE:
Q. All right. You've had a chance to
confer with your attorney and with your husband's
counsel.
Is it your intent to disclose to me
conversations with your husband regarding
allegations of my firm's representation or are you
going to be invoking the husband /wife privilege?
A. Specific conversations?
Q. Yes.
A. I'm not sure what the question is.
Q. Okay. What I'll do is I'll just ask the
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questions and then you can, I guess, decide if
you're going to assert a privilege or not.
Your husband has filed a verified motion
where he has sworn to a number of things.
Have you ever read your husband's
verified motion to disqualify defense counsel?
A. I have not read that.
Q. Okay. I'm going to be asking you
questions about your husband's sworn motion to
disqualify me and I'm going to want to know what
you know about his allegations.
Do you have any independent knowledge
regarding meetings -- alleged meetings with
Mr. O'Hare and me other than from what your husband
told you?
A. I remember how you were referred to us.
I remember him giving me updates. He would talk to
you and you told him something about strategy or he
was gonna call you or you had called him.
Q. Okay. Do you recall any specific
conversation with your husband where he mentioned
my name?
A. Specific conversations?
Not specific conversations.
Q. When is the first time that your husband
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mentioned my name?
A.
Well,
we talked about it together. My
childhood
friend
dated your brother, Louis.
Q.
That was Diane Faulk?
A.
That was Diane Faulk.
Q.
Okay.
And so the first time you heard
my name was in conjunction with Diane Faulk?
A.
Well,
I think you went to Nova High
School, correct?
Q.
I did.
A.
Yeah,
so we went to the same high
school, so --
Q. When did you graduate from Nova?
A. 1974.
Q. So you might have seen me at Nova High
School?
A. I might have seen you --
Q. At Nova High School?
A. That's possible.
Q. Do you recall seeing me since Nova High
School?
A. We've met since then somewhere, but I
don't know where.
Q. Okay. And so the first time you recall
speaking about me was with Diane Faulk?
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A.
Correct, in your capacity as an
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attorney.
3
Q.
And when did you speak to Diane Faulk?
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A.
I don't know.
5
Q.
Was it in 1998? Was it in 1990? Was
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it --
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A.
Back then sometime 15 to 18 years ago,
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whenever we
were involved with Ocean Ridge.
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Q.
Okay. And did you call her because you
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were looking
for an attorney for you or for your
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husband or
for both of you?
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A.
I'm not sure whether I called her or we
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were just
talking and she referred you, but we're
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still close
friends and have been since --
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Q.
And she's a wonderful woman.
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A.
Pardon me?
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Q.
I said she's a wonderful woman.
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A.
Yes.
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Q.
I hold her in the highest regard.
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In terms of -- and her brother, Kenny,
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was a friend of mine who was in my class.
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Dale actually. Dale. Kenny is good
23
friends with
my brother.
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A.
The older brother.
25
Q.
Who's now deceased unfortunately.
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But when you were talking to Diane, you
were specifically looking for an attorney? You
were talking to her about a need for an attorney?
You had some kind of legal issue?
A. I don't remember whether I specifically
asked her did she know someone or whether she
mentioned your name or whether we were talking
about what was happening in Ocean Ridge and she
mentioned your name. I do not recall.
Q. What was the legal issue that you were
concerned with at this time?
A. The legal issue I remember in
Ocean Ridge was our neighbor -- the person that
owned the vacant lot next door was upset with the
roof that we put on because it blocked his ocean
breezes.
Q. Roof on the apartment building?
A. The apartment building.
Q. So you were having --
And then was there some type of a code
violation filed by him or by the City?
A. I don't remember.
Q. So do you recall anything more about the
legal issue that you were speaking to Diane about?
A. No.
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Q. Did you talk to your husband about my
name at that time?
Did you recommend to him that I be
hired?
A. We talked about it, correct.
Q. And what did you --
A. You were referred and we talked about
that and we hired you.
Q. What did you discuss --
A. And you worked for us.
Q. Let's go through those one at a time.
I'm trying to find out what you know --
A. I can't believe you're stabbing us in
the back now after you worked for us. You're
coming back and you're -- you joined the team to
fight against us when you have intimate knowledge
of how Chris uses strategy, intimate knowledge of
his business dealings, and now you're stabbing us
in the back and you've jumped to the other side.
That's not right.
Q. What other side? Who was your --
A. You're now filing suits against Chris on
behalf of Gulf Stream. You're threatening him with
a big RICO action, and you used to work for us.
You're not supposed to do that. As an attorney,
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you're not supposed to do that.
Q. Well, let's go through each of those
things that you've said --
A. Okay.
Q. -- that you apparently have strong
feelings about and appear to know --
A. As I should.
Q. You made a lot of factual assertions and
a lot of legal conclusions, and let's just go
through them one at a time and let's see if they
hold any water, okay?
With regard to the legal issues that you
say I represented you and your husband on that
somehow you're now getting stabbed in the back on
16 years later, can you tell me the first legal
issue you discussed with your husband that you and
he hired me to handle?
A. My husband dealt with you. He handled
the legal issues with the Town of Ocean Ridge and
he dealt with you.
Q. But obviously you have very strong
feelings that somehow I'm stabbing he and you in
the back with regard to a prior representation.
Can you tell me --
A. Because you worked for us before.
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Q.
Tell me what I did for you.
A.
You have worked for us before.
Q.
Okay. I worked for you before.
A.
And now you're on the other side and
you're working
against us. That's not right.
You're not
supposed to do that.
Q.
I worked for you before. Okay. So I
did legal
work for you, but you don't know what it
was, but I
did work for your husband.
A.
You did legal work. You dealt with my
husband.
MR. HANNA: I'm going to object to the
question. Mischaracterizes testimony.
THE WITNESS: Pardon me, Mark?
MR. HANNA: I just was noting an
objection.
BY MR. SWEETAPPLE:
Q. Mrs. O'Hare, can you tell me the legal
work that I did for you and your husband?
A. You represented us. Chris had many
conversations with you about the legal issues. You
represented us in those legal issues for the Town
of Ocean Ridge, and now you're jumping the fence.
You're working for the Town of Gulf Stream against
Chris.
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Q. Can you tell me what those legal issues
were that you say I was representing you on?
A. I don't know.
MR. HANNA: Object. Asked and answered.
MR. ROEDER: Yes.
BY MR. SWEETAPPLE:
Q. Okay. You don't know.
Do you know any of these legal issues
that you say I represented you on?
You mentioned something about a roof on
an apartment building, and other than a roof on an
apartment building, do you know any other matter
that you think I represented you or your husband on
involving the Town of Ocean Ridge or any other?
A. You represented us in the legal issues.
I do not know the specific legal issues. I do not
recall the specific legal issues. You represented
Chris and I in those legal issues. We own the
apartment building.
Q. And you didn't talk to your husband
about these legal issues?
A. No, I did not, not in detail. He dealt
with you. He dealt with the strategy with you, all
of it.
Q. And has he told you recently that I
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represented him with regard to legal issues?
A. It was in the newspaper and he told me.
He was happy when you were hired by the Town of
Gulf Stream. He thought you did a good job for us.
He thought, "Oh, this will be great. Sweetapple's
really gonna do a good job for the Town of Gulf
Stream."
He thought it was a fine thing at first
until you decided to stab him in the back and file
suits against him. Then that's not the right thing
to do, because you've already worked for him. Now
it's -- it's not right.
Q. So have you talked with your husband in
the last three months about my coming in to
represent the Town of Gulf Stream?
A. He told me when you were hired, "Oh,
Sweetapple's gonna represent the Town."
Well, I knew the name right away,
because you represented us in Ocean Ridge, "Oh,
that's good. He'll probably do a good job. That's
great."
Q. And has he told you at any time in this
year that I represented him with regard to legal
issues and represented you with regard to legal
issues in the late 190s?
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A. Did he tell me --
Q. Yeah, in the last six months, has your
husband said to you --
A. He didn't need to tell me. I knew.
Q. Well, did he tell what you these issues
were in the last six months?
Did he ever complain to you that
Sweetapple represented me on such and such issue or
represented us on such and such issue in the late
'90s?
A. Did he ever --
Say that question again.
Did he complain to me --
Q. Let me see if I can lay a predicate for
you.
I asked you what issues you say I
represented you or your husband on in the late
'90s, and you've told me a roof on an apartment
building and that's it.
Now what I'm doing is I'm moving to the
last six months and I want to know about your
communications with your husband during the last
six months.
Did he ever complain to you as to what
issues he said I represented you or he on during
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Page 27
1 the last six months? Did he ever say, "Sweetapple
2 handled this for us in the 190s, this for us in the
3 190s," anything specific?
4 MR. HANNA: I'm going to object to the
5 form.
6 Go ahead.
7 THE WITNESS: Did he say in the last six
8 months what you did for us back in the 190s?
9 BY MR. SWEETAPPLE:
10 Q. That's correct, specifically.
11 A. No.
12 Q. Okay. So as you sit here today based on
13 all the conversations you've had with your husband
14 who you've been with for 31 years, can you tell me
15 what legal work I did for your husband, just a
16 topic?
17 A. What work --
18 Q. Just tell me what matters I handled for
19 him.
20 A. You handled matters for us on the
21 apartment building. We had a neighbor that was
22 upset that we blocked the ocean breezes, and it was
23 with the Town of Ocean Ridge, so it was a town
24 issue.
25 Q. That's the roof issue with the code
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Page 28
violation?
A. I don't know that there was a code
violation. I don't believe there was a code
violation.
Q. Okay. And what other issues has your
husband talked about with you that I represented
you or he on?
A. You represented us back in the 1990s.
Q. You've said that a number --
A. It was with the Town of Ocean Ridge.
You were on our side. You represented us and -- it
was us, and on the other side was the Town of Ocean
Ridge and this neighbor.
Now you're representing a town and
you're filing against us. You're jumping ship and
you're really -- you know, shame on you. You
shouldn't be doing this.
Q. Well, that's what we have laws for and
courts for, and I appreciate the fact that you've
come to a legal conclusion, but I'm trying to
determine facts that would go to a judge's legal
conclusion, so can you tell me any other issues
that you believe as you sit here that your husband
has ever mentioned that I represented him on
besides a roof on an apartment building in
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Ocean Ridge in the late 1990x?
A. I don't know.
Q. Okay. Have you talked to your husband
in the last six months about why he believes I
should not be representing the Town of Gulf Stream
in litigation against him?
A. Yes.
MR. ROEDER: I'll have to object to
that. That's getting down to privileged
information.
MR. SWEETAPPLE: Well, we've already
waived the privilege.
MR. ROEDER: No, we haven't, counsel.
We haven't waived privilege. She has not
waived privilege. That's your
interpretation, which we have to leave for a
judge to decide, quoting you.
MR. SWEETAPPLE: So you're invoking the
privilege now?
MR. ROEDER: You're asking a question
regarding detailed information about what may
have been discussed. That could have
privileged, spousal or even --
MR. SWEETAPPLE: I think she's already
answered five questions on that, but --
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MR. ROEDER: No,
MR. SWEETAPPLE:
not to answer that?
MR. ROEDER: She
She didn't answer any
MR. SWEETAPPLE:
she hasn't.
Are you instructing her
said she didn't recall.
specifics.
Are you instructing her
not to answer?
MR. ROEDER: Yes, I am.
BY MR. SWEETAPPLE:
Q. So you're not going to tell me what you
and your husband discussed during the last six
months about my representation -- my alleged
representation of him?
THE WITNESS: Do I need to refer to my
attorneys on this?
He's saying one thing. You're saying
another.
MR. ROEDER: Don't answer the question.
It's spousal privilege.
THE WITNESS: What is the question again
you're asking me?
BY MR. SWEETAPPLE:
Q. Did you ever -- is it your position that
I represented you with regard to matters in the
past and, therefore, I cannot --
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A. I was an owner of the apartment
building. So it was either Chris and I jointly or
as the LLC. I don't know in the timeline where
that happened, but you represented issues involving
the apartment building with the Town of Ocean
Ridge. So I would consider myself --
Q. And how do you know that?
A. Let me finish, please. You're
interrupting me.
I would consider myself part of that
being that I was part -owner of the apartment
building. Chris handled those issues. Chris is
the one that had the conversations with you.
Q. And Chris told you that, right? Chris
told you that --
A. I got occasional updates from him.
Back in 1998, you were referred by my
childhood friend. We hired you. I talked to Diane
about hiring you. You're a name that we know in
our family.
Q. What I'm asking you is --
A. And now you're working on the other side
against Chris and you have knowledge of --
Q. You're calling me the other side because
I'm representing a town?
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A. Exactly. It was us against the Town.
That was the other side, and now you're on the Town
and you're coming to us, and you're here asking me
questions?
I'm wondering if all of this isn't
privileged, because you've been our attorney before
and now you're here asking questions. It's not
right.
Q. Do you have any knowledge or information
about your allegation that I have represented your
husband in the past that comes from anyone other
than your husband?
A. Do I have knowledge?
Q. Yes.
A. I have personal knowledge that your name
came up numerous times in the 190s that you
represented us.
Q. And who were those conversations with?
A. They were with you and Chris.
Q. You spoke to me?
A. The conversations were with you and
Chris.
Q. Were you party to these conversations?
A. It's very possible I may have overheard
some phone conversations at that time, but I
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remember Chris giving updates, "Sweetapple said to
do this. Sweetapple -- I talked to Sweetapple and
we're gonna do this," so it was conversations.
Q. And so what I'm getting at is that the
only information you have regarding this alleged
representation was what Chris said to you?
MR. HANNA: Object to form.
Mischaracterization.
BY MR. SWEETAPPLE:
Q. Is that correct?
A. This went on for months, Mr. Sweetapple,
and we used to call you Bob, so I guess we're
calling you Mr. Sweetapple now.
Q. You can call me Bob.
A. But this went on for months. This is
not a onetime instance. You and Chris had a
relationship that went on for a long time.
Q. And when you say this went on for
months, you're talking about Chris talking to you
about me?
A. Chris' dealings with you and the issues
with the Town went on for a long time. It wasn't a
one -week deal.
Q. And what I'm saying is -- what I'm
asking you is is all your knowledge about that a
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Page 34
result of your conversations with Chris? Did Chris
have multiple conversations with you about this
over months of time?
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. Let me rephrase it.
Are you saying that Chris had multiple
conversations with you over several months
concerning my representation?
MR. HANNA: Object to form.
THE WITNESS: I don't think it would be
conversations. It would be more like, "I
talked to Sweetapple today and got a
meeting," or something like that.
No, I was very busy at the time. You've
got my calendars. I haven't looked at them,
but I'm a busy person.
BY MR. SWEETAPPLE:
Q. Did he ever talk to you about the legal
issues that you or he claim I was handling?
A. No. I leave that to Chris.
Q. You never talked about the specifics of
any of this representation?
A. It's possible, but I don't recall the
specifics.
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Q. Okay. Now, you know that I'm a trial
lawyer, right?
A. No, I didn't know that.
Q. And I've been a board - certified trial
lawyer for about 25 (sic) years and all I do is try
lawsuits.
Are you aware of whether or not I've
ever appeared in any case for you or your husband?
A. Appeared in a trial? Is that what
you're saying?
Q. No, appeared at a deposition, appeared
at a hearing, appeared at a trial, appeared at a
mediation. That's what I've been doing for 35
years is just appearing at trials, hearings,
depositions, mediations. I don't do closings. I
don't do enforcement hearings. I'm a trial lawyer.
A. Mm -hmm.
Q. So are you aware of any time where I've
ever appeared in any case for you people?
MR. HANNA: Object to form.
Go ahead. You can answer.
THE WITNESS: I think there was
something where you came to the commission
chambers and you talked to the attorneys
there.
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BY MR. SWEETAPPLE:
Q.
Were you present?
A.
No.
Q.
So what are you basing that on?
A.
Information from Chris.
Q.
So Chris told you I was at the
commission
chambers?
A.
Back in 1998, we were having these
legal
issues. I
remember it was you that came in at
the
last minute and worked out the legal issues.
Q.
Well, right now we're talking about
Chris telling you that I appeared at some
commission
chambers.
Was it a hearing?
A.
I think it was at the commission
chambers, but it was at the tail end so that you
wrapped it
up.
Q.
Were you present?
A.
No.
Q.
Was it a hearing?
A.
I don't know what the function was.
Q.
Have I ever been to your house?
A.
I don't think so.
Q.
Has your husband ever told you I've
been
to your house?
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A. Not that I remember.
Q. Have I ever come and picked your husband
up at his house?
A. I don't know.
Q. Has he ever told you I've done that?
A. Not that I remember.
Q. And did you go to --
Did you ever hear of a lawyer named
Edwin Jonas?
A. I've heard the name.
Q. And are you aware whether or not when
your husband came to hire me, Edwin Jonas undertook
to represent him with regard to a code enforcement
violation?
MR. HANNA: Object to form.
THE WITNESS: What was the question?
1•.l'i0 6. 032101:MwTAIVOURMF
Q. Are you aware whether or not --
Did Edwin Jones ever prepare a legal
document for you and your husband with the Town of
Ocean Ridge?
A. I don't remember.
Q. Do you remember his name?
A. I remember the name Edwin Jonas. I
don't know what the context is.
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Q. Did you go to the Town of Ocean Ridge
with your husband and Edwin Jonas and sign a
settlement document?
A. I don't remember.
Q. Do you remember ever signing a
settlement document with the Town of Ocean Ridge
involving this apartment building?
A. No, I don't.
Q. Are you aware of any document --
I see you brought your calendars with
0AMO e
A. I didn't bring them.
Q. Well, your lawyer brought them or your
husband's lawyer brought them.
Do you keep cancelled checks for checks
that you've written?
A. Not after seven years.
Q. Do you keep files, legal files?
I see you have your calendars.
Do you keep your legal files more than
seven years?
A. No.
Q. Are you aware of my name appearing -- do
you have any document that my name appears on that
I've signed?
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A.
I don't know.
Q.
No notice of appearance in a case?
A.
I don't know.
Q.
So do you know if your husband did a
search of
newspaper articles to see whether or not
I was mentioned
in any newspaper articles involving
the two of
you?
A.
I don't know.
Q.
Have you ever discussed that with him?
A.
No.
Q.
Did he ever use your credit card to run
a search of newspapers to see whether or not I was
named in any newspaper articles?
A.
Not that I know of.
Q.
Do you have any newspaper articles that
I've been
named in where I've done anything for
either of
you?
A.
What's the question?
Q.
Do you have any newspaper articles where
I've done
anything for you?
A.
No.
Q.
Do you have any documents that you've
seen where I or my firm have done any legal work
for you in any form?
A. Do I possess any documents?
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aMe
Q. Have you ever seen any?
A. I don't know.
Q. And you haven't looked for any?
A. I have not looked for it.
Q. And you haven't read your husband's
sworn motion to disqualify me?
A. No.
Q. Okay. So your conclusion here that
you've lectured me on is that if me or my firm
represented you or your husband with regard to a
roof in Ocean Ridge, that I can't represent the
Town of Gulf Stream in a lawsuit that he's brought
against the Town of Gulf Stream?
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. Let me rephrase that.
Are you aware that the case that I've
appeared in that I'm handling is a case that your
husband has brought against the Town of
Gulf Stream?
MR. HANNA: I'm going to object to form.
BY MR. SWEETAPPLE:
Q. Are you aware of that?
A. Was I aware --
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Q. Are you aware that I'm representing the
Town of Gulf Stream in one of many cases that your
husband has seen fit to bring? Are you aware of
that?
A. No.
Q. Do you know what that case involves?
A. No.
Q. Are you aware that case involves a
request for public records?
MR. ROEDER: She just said she didn't
know.
THE WITNESS: I don't know.
BY MR. SWEETAPPLE:
Q. Does that refresh your recollection that
the case involves a request for public records?
A. No, I don't know.
Q. Do you know how many requests for public
records your husband has made to the Town of
Gulf Stream?
A. No.
Q. Do you have any idea at all?
A. No.
Q. Do you know whether or not he's ever met
with Mr. Chandler, Joel Chandler?
A. I believe so.
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Q. And you've met with Mr. Chandler, right?
A. I met him.
Q. Right, and when you met with --
When did you meet with Mr. Chandler and
your husband? Was that last year, 2013?
A. I didn't meet with Mr. Chandler and my
husband.
Q. Who did you meet with, just
Mr. Chandler?
A. I met Mr. Chandler. I did not meet with
Mr. Chandler.
Q. Were you present when Mr. Chandler was
speaking with your husband?
A. No.
Q. Are you aware that your husband met with
Mr. Chandler to discuss filing hundreds of public
records requests?
A. No.
Q. Are you aware that your husband has
filed hundreds of public records requests?
A. No.
Q. Have you ever met Mr. O'Boyle?
A. Yes.
Q. And are you aware of whether or not your
husband communicates with Mr. O'Boyle?
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MR. ROEDER: For the record, can we be
specific?
MR. SWEETAPPLE: Yes. Martin O'Boyle.
THE WITNESS: Say that again, please.
BY MR. SWEETAPPLE:
Q. Are you aware whether or not your
husband ever met and talked with Mr. O'Boyle about
filing hundreds of public records requests to the
Town of Gulf Stream?
A. No.
Q. When you met with Mr. Chandler, where
did you meet with him?
A. My husband's office.
Q. And why were you there?
A. I don't remember.
Q. And who was there?
A. Lou.
Q. And your husband?
A. No.
Q. Just Lou. Okay.
And did you hire Mr. Chandler? Did you
or your husband hire Mr. Chandler?
A. I don't know.
0. Was Mr. Chandler a consultant on how to
bring public records requests?
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A. I don't know.
Q. Did you and -- did Mr. Chandler ever
discuss with you how to make a AAA public records
request or a kill shot in order to collect money?
A. No.
Q. Have you ever talked with your husband
as to why he files public records requests against
the Town of Gulf Stream?
A. Pardon me?
Q. Have you ever discussed with your
husband as to why he files public records requests
with the Town of Gulf Stream?
A. In some general terms.
Q. What has he told you?
A. That the Town is not applying the law
fairly to all the people in the town and that the
law is not spelled out clearly.
Q. And that's why he's filing hundreds of
public records requests?
A. I don't know.
Q. Has he ever told you he's filing public
records requests using fake names?
A. No.
Q. Has he ever discussed with you whether
or not the O'Boyles are filing hundreds of public
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records requests under the names of alleged
not - for - profit companies?
A. No.
Q. What has he told you about the public
records requests he's filed?
Has he ever told you that he spent a
Sunday just writing up dozens of public records
requests?
A. Has he ever said what?
Q. That he just would spend a Sunday
writing dozens of public records requests and
delivering them to the Town on Monday.
MR. HANNA: I'm going to instruct the
witness not to answer. Mr. O'Hare is going
to invoke his spousal privilege regarding any
conversations he had regarding making public
records requests.
It's also -- the subject matter of the
deposition at this point is for the
disqualification motion and the prior
representation.
MR. SWEETAPPLE: No, no, no. I'm
taking -- I view your motion to disqualify as
an utter sham and I am looking forward to
having a hearing on it, but I'm not going to
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bring her back for a second deposition other
than to move to compel documents and any
unanswered questions. I'm taking this
deposition for purposes of the motion to
disqualify and, also, with regard to the
claims I'll be filing against --
MR. HANNA: All I did was invoke the
privilege, so you can move on and ask your
next question.
MR. SWEETAPPLE: But I don't want to
leave on the record your statement that this
deposition is only about disqualification.
MR. HANNA: That's my position.
MR. ROEDER: I also object for the
record as her attorney that the deposition
has been noticed for the disqualification.
There was no notice for the -- it was in the
case regarding the public records request,
but it was for purposes of disqualification.
MR. SWEETAPPLE: Well, I subpoenaed her
in this case and I'm filing affirmative
defenses and counterclaims in this case,
okay? And so I'm taking her deposition with
regard to Mr. O'Hare's, Mr. O'Boyle's, his
fictitious names, the fake not - for - profits,
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Page 47
1 all of the thousands of requests that have
2 been filed under the pretense of open
3 Government for the purpose of closing
4 Government. So I'm taking this deposition to
5 the extent that I am permitted with regard to
6 this case. This notice is not limited to --
7 MR. ROEDER: I put my objection on the
8 record. I didn't need to pontificate.
9 THE WITNESS: If he's gonna call me back
10 for a second deposition, why don't we just
11 close this right now, then you call me back
12 and then you can discuss that and we can
13 figure out whether or not you can ask me
14 those questions.
15 MR. SWEETAPPLE: What I am --
16 MR. HANNA: Let's move on with the
17 questioning.
18 MR. SWEETAPPLE: Let's go forward.
19 BY MR. SWEETAPPLE:
20 Q. Are you aware whether or not your
21 husband has filed suit against Gulf Stream?
22 A. Am I aware that what?
23 Q. Whether or not he's filed any lawsuits
24 against Gulf Stream.
25 A. Am I aware?
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Yes.
Q. How many lawsuits has he filed?
A. I don't know.
Q. And what do they allege?
A. I don't know.
Q. Have you ever read them?
A. No.
Q. Without telling me what you discussed
with him, have you ever discussed them?
A. Not specifically.
Q. When you met with Mr. Chandler, were you
discussing public records requests?
A. I was discussing what I had heard about
Mr. Chandler.
Q. What had you heard about Mr. Chandler?
A. I heard that Mr. Chandler was going from
town to town doing public record requests as a
course of making a living.
Q. And what did you tell him?
A. I thought that was sleazy.
Q. And did you discuss anything beyond that
with him?
A. Anything what?
Q. Strike that.
What did he say to you exactly in terms
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of going around town to town making public records
requests to make a living?
MR. HANNA: Who are you referring to,
Joel?
BY MR. SWEETAPPLE:
Q. Joel Chandler. What did he say to you?
A. I don't recall.
Q. Why did you come to believe that
Mr. Chandler was going around town to town making
public records requests?
A. I'd heard that.
Q. From whom?
A. I don't remember where. Lou was there.
I don't know.
Q. So were you there for the purpose of
meeting Mr. Chandler or he just --
A. No.
Q. -- happened to be there?
Did Mr. Chandler make you aware that he
was there to consult with your husband to help him
make public records requests?
A. No.
MR. HANNA: I'm going to object to form.
BY MR. SWEETAPPLE:
Q. Did you know if your husband ever paid
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Mr. Chandler any money for coming to help him make
public records requests?
A. No.
Q. What did Mr. Chandler say when you told
him that you thought what he was doing was sleazy?
A. I don't recall.
Q. Do you know if your husband has ever
consulted with Mr. Chandler?
MR. HANNA: Objection. Asked and
answered.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. Did you ever say to Mr. Chandler that
your husband was doing what he was doing just to
get a roof -- get a solar roof and that you thought
that what everyone was doing was sleazy?
MR. HANNA: Object to form.
MR. ROEDER: Objection.
THE WITNESS: What's the question?
BY MR. SWEETAPPLE:
Q. Did you discuss in Mr. Chandler's
presence the fact that your husband was upset that
he did not get a solar roof from the Town of
Gulf Stream?
A. No.
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Q. And did you ever say to Mr. Chandler
that you believe that what your husband was doing
was sleazy?
A. I don't know. I doubt it.
Q. Did you know when Mr. Chandler was there
that he was there to assist your husband in filing
public records requests?
MR. HANNA: Object to form.
THE WITNESS: No.
BY MR. SWEETAPPLE:
Q. Do you know if Mr. Chandler has ever
worked with Mr. Roeder and your husband for
purposes of showing them how to make public records
requests?
A. No.
Q. And why did you understand -- if this
man was sleazy doing sleazy things, why did you
think he was in your husband's office?
A. I went in the conference room and Lou
was there and Lou introduced me to Mr. Chandler.
Q. And did you know anything about
Mr. Chandler before you met him?
A. I had heard that he was making public
record requests to different towns.
Q. Who did you hear that from?
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A. I don't know.
Q. Had you already formed an opinion that
Mr. Chandler was doing sleazy things before you met
him?
MR. HANNA: I'm going to object to form.
THE WITNESS: I don't know.
BY MR. SWEETAPPLE:
Q. Or did you make that conclusion after
you met with him at your husband's office?
A. I don't know.
Q. Did Mr. Chandler describe to you what
his modus operandi was, the way he operated was?
A. No.
Q. Did he ever tell you that in the fall of
2012, an attorney asked him to come up with public
records request cases and he was able to bring him
101 cases in the space of about six weeks?
MR. HANNA: I'm going to object to form.
BY MR. SWEETAPPLE:
Q. Did Mr. Chandler ever tell you that in
the fall of 2012 --
A. I did not meet with Mr. Chandler. I met
Mr. Chandler and spoke with him for a total of
about 60 to 90 seconds. So no, he didn't get into
any specifics. There's no need to ask me questions
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Page 53
about specific conversations that Mr. Chandler had
and whether I remember those conversations. I did
not meet with Mr. Chandler. I just met him.
Q. But you told me that you concluded for
some reason that what Mr. Chandler was doing was
sleazy, right?
A. I didn't like him.
Q. And did he tell you what he was doing?
A. I don't remember.
Q. Did he ever tell you that he was helping
your husband?
A. No.
Q. Was there any discussion of your husband
using public records requests in order to pressure
the Town into getting his roof approved?
MR. HANNA: Object to form.
THE WITNESS: What was the question?
BY MR. SWEETAPPLE:
Q. Do you recall any conversations with
Mr. Chandler when you were present with him at your
husband's office where getting an approval from
Gulf Stream on a roof was discussed?
A. No.
Q. Did you tell Mr. Chandler you thought
what he was doing was sleazy?
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A. I may have.
Q. Did you tell anyone else you thought
what he was doing was sleazy?
A. Did I tell him what?
Q. Did you tell anyone else that you
thought what he was doing was sleazy?
A. No.
Q. And do you know if your husband or any
of his attorneys ever gave money to Mr. Chandler?
A. No.
Q. And the prior representation you say I
was involved in in 1998, did any of that involve
public records requests?
A. I don't know.
Q. Okay. Let's go through these documents
that were produced by --
MR. SWEETAPPLE: I guess, Mr. Hanna, you
produced these or --
MR. ROEDER: I did.
MR. HANNA: Yeah.
MR. SWEETAPPLE: And you've asked
Mr. O'Hare to get these I take it?
Mrs. O'Hare doesn't know what they are?
MR. HANNA: They were given to me in
response.
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BY MR. SWEETAPPLE:
Q. All right. Mrs. O'Hare, you did not --
I'm going to show you --
I'm going to mark what's in front of
you --
Are they marked as 1 and 2?
A. Correct.
Q. And I'm hoping that 198 is 1 and 199 is
2. Maybe we got lucky.
A. Yes, that's correct.
Q. You did not look for these documents,
right?
A.
That's correct.
Q.
Your husband found
these, right?
A.
We have them.
Q.
Did you give these
to your husband?
A.
We have a box that's
just marked
" Daytimers" where we keep our
daytimers.
Q.
Is this your daytimer or his daytimer?
A.
This looks like my
daytimer.
Q.
Did you each have your own daytimers?
A.
Yes.
Q.
And let's go with Exhibit 1, which is
1998, and
let's look at every
entry that you
believe refers to some aspect
of my firm or me
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Page 56
representing you, okay?
MR. ROEDER: Just for the record, make a
note that she doesn't have tabs on hers.
Hers are clean. Yours are the one we had
tabs. We gave you tabs so it would be easier
for you to --
MR. SWEETAPPLE: These yellow tabs?
MR. ROEDER: No, the tabs on -- we
explained to you --
MR. SWEETAPPLE: On the top?
MR. ROEDER: Yes.
MR. SWEETAPPLE: She doesn't have that
on hers?
MR. ROEDER: She doesn't have that.
MR. SWEETAPPLE: Okay. Then let's
switch. Let me give you the ones that are
tabbed.
MS. O'CONNOR: I tabbed those.
BY MR. SWEETAPPLE:
Q. Did you write
someone else write notes
MR. ROEDER:
THE WITNESS:
That's outside the
the page ends.
notes on the top or did
on the top?
le's referring to these.
I did not write these.
page. You can see where
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BY MR. SWEETAPPLE:
Q. Right, but that was written by someone
else?
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A.
That's not my handwriting.
Q.
Do you know who wrote it?
A.
Looks like Chris' handwriting.
Q.
Did you go through these calendars to
see if there were any entries regarding me or my
firm
--
A.
No.
Q.
-- or did your husband?
A.
Did I go through any calendars to see if
there
were
entries?
Q.
Right.
A.
No.
Q.
Did you go through these calendars?
A.
No.
Q.
So do you know if your husband wrote
those
tabs
on the top of the pages?
A.
This that's outside the page?
Q.
Yes.
A.
I don't know if he wrote it. It looks
like
his handwriting. You could ask him. He's
right
here
at the table.
MR. HANNA: Mr. O'Hare got these records
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Page 58
from their files when he was searching to
comply with your request for production. He
went through and tabbed the stuff that could
be relevant to the Ocean Ridge litigation in
general and if your name was mentioned,
because you'll see in some of it it has Heath
King or referring to Ocean Ridge town
meetings, a press conference that you guys
had for the code enforcement.
MR. SWEETAPPLE: That you guys had?
MR. HANNA: Yes.
BY MR. SWEETAPPLE:
Q. Okay. Let's go through them.
This is the first time you've looked at
this calendar?
A. In many years.
Q. So despite the fact that I asked you to
go through your records in the subpoena, we're now
going to have to go through this for the first time
here in the deposition, which is unfortunately
going to take us a little bit longer, but let's
start with the first page and look and see whether
or not there's anything on the first page that you
believe refers to me or my firm, and note you have
your husband's notes there to help you.
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A. Is there anything on this page that
what?
Q. That refers to your allegation that me
or my firm represented you or your husband in 1998.
A. You're welcome to look at that page,
also, and see if you see anything that refers to
you.
Q. I have Exhibit 1 in front of me and I'll
follow along with you.
MR. HANNA: He has the same page.
MR. SWEETAPPLE: I'm not the witness.
THE WITNESS: He's asking me. Well, you
know, it's like you've got it in front of
you, too, so you can look, too.
BY MR. SWEETAPPLE:
Q. You're the witness and I'm just asking
questions. So tell me, please, what on page -- on
the January 1, 2, 3, 4 page of 1998 of Exhibit 1 of
Shelley's calendar that you believe refers to
representation by me or my firm.
A. I see, "Meeting re: settlement," on
January 27th at eight.
Q. January what?
A. 27th.
Q. Okay.
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A. "Meeting re: settlement."
Q. I'm looking at 198. I think maybe we
need to mark -- you're looking at 199 maybe.
MR. ROEDER: She's looking at 198,
January 27.
BY MR. SWEETAPPLE:
Q. Okay. Well, the first day on my 198
is -- the first page is 1, 2, 3 and 4.
A. You have January 4th. Mine at the top
is January 26th.
MR. HANNA: Yeah, here's the -- that was
the one page. That doesn't have the tab on
it I don't think.
BY MR. SWEETAPPLE:
Q. Put this as part of your --
MR. ROEDER: Oh, she was missing the
cover page.
BY MR. SWEETAPPLE:
Q. Yes, you were missing the cover page.
So is there anything on page 1, which is
January 1, 2, 3, 4?
A. No.
Q. Did you keep this calendar yourself,
Exhibit 1?
A. Did I write these entries?
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Q. Yes.
A. This looks like my handwriting, yes.
Q. And was it for your appointments or was
it for your and your husband's appointments?
A. Sometimes if there was something coming
up and I knew about it in the future, I would
circle and I would keep track of it, but mostly for
me.
Q. Did you also write his appointments down
in it?
A. Sometimes I would.
Q. To remind him?
A. No, just for my knowledge. He's gonna
be somewhere. I'm gonna to be somewhere.
Q. Okay. So on the first page of
Exhibit 1, do you see anything that you believe
relates to alleged representation by me or my firm?
A. No.
Q. Let's go to page 2.
A. What date do you have at the top?
Q. I have January 26, 27, 28 on my page 2.
A. All right.
Q. Is that consistent with you?
A. Yes.
Q. Can you please tell me what you believe
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in your calendar relates to any alleged
representation by my firm?
A. I see 8 a.m. on the 27th, "Meeting
re: settlement."
Q.
I'm sorry. Where is it, 27th?
"Meeting re: settlement."
How does that tell you that in any way
related to
me or my firm?
A.
Possibly. If it was a settlement with
the Town of Ocean Ridge, I don't know.
Q.
So you don't know what this is about,
this settlement that's listed here?
A.
I don't remember.
Q.
Was your husband involved in any other
matters in
January of 1998?
A.
I don't know.
Q.
Was he a party to any lawsuits?
A.
I don't know. I don't believe so.
Q.
Did he have an attorney -- any other
attorneys?
A. No.
Q. No?
Who represented --
A. We would have an attorney for a real
estate closing.
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Q. Was he involved in any litigation with
your neighbor or the Town in January of 1998?
A. I don't know.
Q. So you really don't know what this
entry, "Meeting re: settlement," refers to?
A. No.
Q. And who told you to put that in there?
Does this refer to your husband's
meeting --
A. I don't know.
Q. -- your meeting?
Whose meeting does this refer to?
A. I've just told you I don't know.
Q. You don't know if it was your meeting or
his meeting?
A. I would not be attending a meeting
regarding a settlement.
Q. That's what I'm trying to ascertain
then.
Do you know this related to your husband
having a meeting?
A. I don't know.
Q. You don't know. Okay.
Let's go, please, to the next page that
you believe might have any reference to
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representation by me or my firm of you or your
husband.
A. Say that again, please.
Q. Please go to the next page --
A. All right.
Q. -- and tell me any entry that you
believe has or may have any relationship to alleged
representation by me or my law firm of you or your
husband.
A. I see there's a special meeting at town
hall. I don't know what that's about.
Q. What date is that?
A. May or may not have to do with your
representation for us at that time.
Q. What date is that? What date?
MR. ROEDER: Just if you go off the
record --
THE WITNESS: "Special meeting," Friday
the 13th, 1998.
BY MR. SWEETAPPLE:
Q. Of February?
MR. ROEDER: If you could just go off
the record for just a moment with your
permission.
You weren't here at that time. We told
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the videographer. Shelley has a hearing aid.
She has a hard time hearing, so you may have
to speak up. She's not ignoring you or not
understanding your question. Sometimes she
just doesn't hear it.
MR. SWEETAPPLE: Okay. I'm sorry. I
didn't know that.
MR. ROEDER: I just want to make that --
BY MR. SWEETAPPLE:
Q. All right. If you don't hear me, let me
know.
A. I do.
Q. Okay. All right.
So February 13 is the date of this entry
and it's, "Special meeting town hall," right?
A. Mm -hmm.
Q. "Special meeting town hall."
Was your husband on the city council at
this time?
A.
I
don't
remember.
Q.
Do
you
know if this was a council
meeting?
A.
I
don't
remember.
Q.
Do
you
know who went to this meeting?
A.
Do
I know
what?
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Q. Who went to the meeting.
A. No.
Q. Do you know if I was at the meeting?
A. No.
Q. Have you gone to look at any minutes of
a special meeting to see who was there?
A. No.
Q. All right. What's the next entry you
believe may relate to representation by me or my
firm?
A. Well, I'm going up here on the top. Let
me read each one.
"Town hall research," that may have to
do with you.
Q. Your husband wrote that down, wrote that
it might have something to do with me?
Do you have any knowledge if, "Town hall
research," has to do with me?
A. No.
Q. You're talking about March 13 where it
says, "Town hall research."
You don't know if that has to do with me
or not, correct?
A. Correct.
Q. All right. What else in your calendars
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do you believe or based on your husband's review?
A. What is the question?
Q. What's the next item in the calendar --
I recognize you didn't make these
notations. Your husband did. So I'm giving you an
opportunity to look at anything you or your husband
indicated --
A. Are you saying he asked me to make the
notations in my calendar?
Q. No, he made the notations on the top
that you're looking at.
MR. HANNA: The little sticky note.
THE WITNESS: Okay. Yeah, but I'm not
looking at that. I'm just looking through
it.
BY MR. SWEETAPPLE:
Q. Well, don't overlook his notes, because
I'm letting you look at those to clue you in to
what he says may be. So keeping in mind --
You look at the page and also look at
his notes and tell me what else you believe --
A. Oh, "Comm meeting," is probably
commission meeting.
Q. What date?
A. Monday, the 6th.
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Q. May 6th?
A. April 6, 1998.
Q. Before you get to May, let's go back to
April. It says:
"Press conference at apartment four
to eight."
Are you saying I was at a press
conference?
A. Oh, "Press conference at apartment."
Q. Yeah, four to eight on April 6th.
You said something about me being at a
press conference.
MR. HANNA: I said that.
MR. SWEETAPPLE: Okay.
THE WITNESS: I don't know.
BY MR. SWEETAPPLE:
Q. Was I at a press conference on
April 6th?
A. I don't know.
Q. Have you seen any document that
indicates I was at a press conference?
A. Chris dealt with you. You were our
attorney for the apartment building in our legal
matters in the Town of Ocean Ridge.
Q. Okay, but that's not my question.
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A. You were our attorney.
Do you remember being our attorney?
You worked for us, Bob. You were our
attorney, and now you're -- you've jumped the
fence. You're coming at us from the other side.
You were our attorney.
Q. I don't think you have any idea what
legally went on in 1998, and you've convinced me
that you don't have any idea what's going on now.
MR. HANNA: I'm going to object.
THE WITNESS: But once an attorney's
worked for you, you can't go to the other
side.
MR. HANNA: Just ask questions.
MR. SWEETAPPLE: I would suggest to you,
ma'am, that your knowledge that you're
stating of the law is almost as undetailed
and uninformed as your knowledge of what your
legal issues were in 1998 and your knowledge
of what your husband's doing now.
MR. O'HARE: Why don't you just tell her
she's stupid?
MR. HANNA: Okay. Everybody calm down.
MR. SWEETAPPLE: I'm not saying that.
I'm saying you're giving me your legal
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opinion and it's really not valid.
MR. ROEDER: Objection. You're giving
your legal opinion, and I've been quiet
through this whole thing. So let's just ask
a question and she'll answer the question.
MR. SWEETAPPLE: So read back what she
said. Read back what she said, please, so
she can hear it and then I want to ask her a
question about it.
(Reporter reads as requested.)
BY MR. SWEETAPPLE:
Q. Mr. Hanna made the statement that I
appeared at a press conference.
Are you aware of me appearing at any
press conference on behalf of you or your husband?
MR. HANNA: I'm going to object to form.
It mischaracterized my statement. I said you
all had a press conference.
MR. SWEETAPPLE: Who's you all?
MR. HANNA: Just the people involved
with the Town of Ocean Ridge, this code
enforcement hearing. My understanding was
that it was part of your representation, but
that's my knowledge. Don't put it on her.
MR. SWEETAPPLE: Are you making a
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statement on the record that I appeared at
some press conference?
MR. HANNA: No. I'm clarifying that
that wasn't her statement. I said that.
MR. SWEETAPPLE: Okay. But I'm asking
you, are you saying on the record that I --
MR. HANNA: Ask her a question. That's
what the deposition is about, not making
speeches, asking questions.
MR. SWEETAPPLE: Okay. Well, you made a
statement on the record. I wanted to see
whether or not you were prepared to clarify
it more.
BY MR. SWEETAPPLE:
Q. Are you aware if I ever appeared at any
press conferences for you or your husband?
A. No.
Q. But your husband did write, "Press
conference at A -P -T," apartment, "Four to eight
3 p.m."
MR. ROEDER: Objection. That's your
interpretation that he wrote that.
BY MR. SWEETAPPLE:
Q. Is this your husband's --
Are you aware whether your husband wrote
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what's on --
A. It looks like his handwriting. That is
not written -- that's not part of my calendar.
MR. ROEDER: It was not clear whether
you were talking about the Post -It note or
whether you were talking about --
BY MR. SWEETAPPLE:
Q. About the Post -It note.
Your husband did write, "Press
conference at apartment four to eight 3 p.m.,"
suggesting that that was something that related to
my representation, right?
A. I don't know his intention when he was
writing that.
Q. All right. Let's go to the next page,
which is April 13:
"O.R. hearing, 8 a.m., 4/14."
A. "Hearing town hall," is in my calendar.
Q. And do you know who appeared at that
hearing? Do you know who appeared at that hearing?
A. No.
Q. Do you know if you went to town hall on
April 13th?
A. Do I know if I went to town hall
April 13th?
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Q. Yes.
A. I do not recall.
(The document referred to was thereupon
marked Defendant's Exhibit No. 3 for
identification, a copy of which is
attached hereto.)
BY MR. SWEETAPPLE:
Q. Let me show you what I'm marking as
Exhibit 3 to your depo. It was No. 2 to your
husband's depo, and this is a stipulation and order
from the code enforcement special master, Town of
Ocean Ridge, and have you ever seen that
stipulation and order before?
A. I don't recall seeing this, but this
looks like my signature and I probably have.
Q. Okay. Take a look at it and see if this
refreshes your recollection that you were at town
hall on the 13th of April, 1998 as shown on the
calendar and that you were there --
A. Pardon me, Bob. Could you speak up,
please?
Q. I should look up when I'm talking, yeah.
Please look at Exhibit 3, and after you
look at it, please tell me if this refreshes your
recollection that you, your husband, Edwin Jonas
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and Paul Nicoletti were at town hall when this
agreement was signed.
A. I don't recall this.
Q. Do you recall being at town hall on the
13th of April, which was a Monday, in 1998 with
your husband?
A. I don't recall.
Q. Do you recall meeting a man or knowing a
man by the name of Edwin Jonas at that meeting?
A. No.
Q. Did you ever meet a man named Paul
Nicoletti, the town attorney?
A. I know the name. If we signed this, we
probably met. I don't recall meeting him.
Q. So you don't recall anything about when
this was signed?
A. No.
Q. Other than this is your signature?
A. (Witness moves head up and down.)
Q. Okay. You don't know how you went to
town hall that day or anything about this day; is
that correct?
A. I don't recall.
Q. Do you recall how the dispute involving
the roof was ultimately resolved?
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A. I think you swooped in and resolved it
for us.
Q. You think I swooped in and resolved it?
A. But no, I don't recall.
Q. And who told you I swooped in and
resolved it?
A. I think that's what you did as our
attorney.
Q. But based on --
Who told you that? Did your husband
tell you that?
A. No.
Q. Well, do you have any recollection of me
swooping in like with a cape or something?
A. You worked for us. You worked for us
through this whole -- all of these legal issues.
You worked with us on it.
Q. I've heard you say that without giving
me any specifics that you know about, and you've
told me I swooped in and I resolved this.
A. You did your job. Thank you.
Q. Mr. Nicoletti has filed an affidavit
contrary to your husband's testimony that I wasn't
even present at that execution.
MR. HANNA: I'm going to object to form.
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MR. ROEDER: Mischaracterization.
BY MR. SWEETAPPLE:
Q. So what I'd like to know is did I swoop
in and come to that meeting?
A. I don't recall.
MR. HANNA: Object to form.
BY MR. SWEETAPPLE:
Q. Mr. Nicoletti has filed an affidavit he
doesn't recall ever having met me.
Are you aware of that?
MR. ROEDER: If you have an affidavit,
can you produce it?
MR. SWEETAPPLE: I filed it in this
cause.
MR. ROEDER: Can you produce it here?
BY MR. SWEETAPPLE:
Q. Have you seen the affidavit I filed in
this cause?
A. No.
Q. Has anybody before this deposition
bothered to tell you anything at all about this
case?
A.
Lou
gave
me instructions to
tell the
truth, go
into
this
deposition and tell
the truth.
Q.
And
you
told me you heard of
Edwin
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Jonas.
How did you hear of Edwin Jonas?
A. I don't recall.
Q. Were you aware that Edwin Jonas
represented you at the time that you signed
Exhibit 3?
A. No.
Q. Do you know what Edwin Jonas'
relationship was with my law firm?
A. No. I see his name here, but --
Q. Are you aware that Edwin Jonas was of
counsel to my firm --
A. No.
Q. -- for a period of time?
A. (Witness moves head from side to side.)
Q. Did your husband ever tell you that
Edwin Jonas was representing him with regard to the
code enforcement case?
A. I don't know.
(The document referred to was thereupon
marked Defendant's Exhibit No. 4 for
identification, a copy of which is
attached hereto.)
BY MR. SWEETAPPLE:
Q. Let me show you what I'm going to mark
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as Exhibit 4 -- it was 3 to your husband's
deposition -- and ask if you've ever seen this
letter before.
MR. HANNA: What is this?
MR. SWEETAPPLE: This is 4.
BY MR. SWEETAPPLE:
Q. You see the date that we were retained?
It says April 7th we were recently
retained.
You see that?
A. Mm -hmm.
Q. So that would tend to show that these
entries in January and February and March that your
husband marked with his stickies may not actually
refer to my firm, right?
MR. ROEDER: Objection.
THE WITNESS: I don't agree with that.
Page 78
BY MR. SWEETAPPLE:
Q. So do you know if April 7th was when our
firm was recently retained by Christopher O'Hare?
A. In the letter dated April 7th, it says:
"Please be advised that our firm was
recently retained by Christopher O'Hare."
Q. In reference to a code enforcement
special master proceeding scheduled for Tuesday,
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Page 79
1 April 14, 1998 at 8 a.m., right?
2 A. That's what this letter is in reference
3 to.
4
Q.
And you see who it's signed by?
5
A.
It's on your letterhead, Sweetapple,
6
Broeker &
Vargas.
7
Q.
I see that.
8
A.
And it's signed by Edwin Jonas, of
9
counsel for the firm.
10
Q.
Okay. Did your husband ever tell you
11
that Mr. Jones was working with him on the code
12
enforcement matter --
13
A.
I don't know.
14
Q.
-- not me?
15
A.
I don't recall.
16
Q.
Okay.
17
A.
Edwin Jonas was not a household name
18
like your
name was a household name.
19
Q.
Okay. And the letter, Exhibit 4, is
20
dated April
7th, and Exhibit 3, the final order, is
21
dated April
14th, right?
22
A.
Which is Exhibit 3?
23
That's Exhibit 2.
24
Oh, Exhibit 3 is the letter.
25
MR. ROEDER: No, Exhibit 4 is the
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letter.
BY MR. SWEETAPPLE:
Q. That's April 14th, right?
MR. ROEDER: This is Exhibit 3 right
here.
THE WITNESS: This says Exhibit 3.
MR. HANNA: That's for Chris'
deposition.
Debra Duran & Associates
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Page 80
MR. ROEDER: This is 4.
THE WITNESS: What's the question?
BY MR. SWEETAPPLE:
Q.
The letter saying we were recently
retained
was dated April 7, 1998, and the
stipulation
and order is a week later dated
April 14,
1998.
Do you see that?
A.
It was signed April 13th and --
Q.
The final order is April 14th.
A.
The 14th.
Q.
So that's a week after Mr. Jonas wrote
and said
that our firm was retained, right?
A.
April 7th to April 14th equals one week,
correct.
Q.
Right. What do you allege that my firm
handled or
that I handled for you --
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Page 81
A. I have no opinion on that.
Q. What factually -- I've heard you say at
least a dozen times, "You worked for us. You
represented us. You jumped the fence," and what
I'd like to know is after my firm through Mr. Jonas
in one week succeeded in closing a code violation
matter with the Town of Ocean Ridge --
A. Well, actually, it looks like Mr. Jonas
was hired before the 7th, right, because it says
like in the past tense, "Our firm was retained by
Christopher O'Hare," and that was written
April 7th. So it was really before April 7th that
your firm was retained.
So what is the one -week period you're
getting at again?
Q. The period from April 7th to April 14th.
A. Okay. That's the difference between the
date of the letter and the date of this, but it
looks like when he says it's dated April 7th --
It says:
"Please be advised that our firm was
recently retained by Christopher O'Hare."
So that's saying it was retained --
Q. In reference to a code enforcement --
A. -- E -D. It's in the past tense. So
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Pagc 82
it's before April 7th. Could have been way before.
Could have been a week before. His definition of
recently is very subjective.
Q. Well, instead of talking about time,
let's talk about matters.
A. Okay. So you're dropping the week
thing. So from April 7th to April 14th, we're not
on that anymore.
Q. I'm not going to debate with you whether
or not we handled the code enforcement matter for
seven days or 14 days or 30 days.
What I'd like to know is after April 14,
1998, what legal matters are you claiming that I
represented you and your husband on?
A. I don't recall.
Q. Give me some idea of some legal matter
that you think I might have represented you or your
husband on.
A. I have no opinion on that. I don't
recall the dates from 1998.
Q. Give me any other issue that I could
have possibly been representing your husband on
that you had some knowledge of in the late 190s.
A. What is the question?
MR. SWEETAPPLE: Please read my question
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 83
1 back.
2 (Reporter reads as requested.)
3 THE WITNESS: We had legal issues with
4 the Town of Ocean Ridge. You represented us
5 on those legal issues. I do not recall the
6 specific time frame in which you represented
7 us.
8 BY MR. SWEETAPPLE:
9 Q. What were those issues? What were those
10 issues?
11 A. Our neighbor complained that we were
12 blocking his ocean breezes. I don't recall the
13 specifics. You communicated with Chris. You
14 worked on strategy with Chris. You worked it out
15 with Chris. You know --
16 Q. Regarding the roof on the apartment?
17 A. Our neighbor was complaining that the
18 roof restricted his ocean breezes.
19 Q. Any other issue that you believe that I
20 had any involvement in on behalf of your husband?
21 A. I was not involved in those issues. You
22 communicated with Chris. You strategized with
23 Chris. You handled all of the issues with Chris --
24 Q. Okay.
25 A. -- on those. You represented us, but
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Page 84
you worked through Chris representing the apartment
building that we had at that time.
Q. Did you ever receive a bill from my law
firm?
A.
I don't
recall.
Q.
Did you
ever receive
any writing from my
law firm?
A. Well, this is not addressed to me. I
don't recall.
Q. All right. Let's keep going through
Exhibit 1.
What's the next matter that you
believe --
A. April 13th.
Q. Didn't we do April 13th?
MR. HANNA: Yeah, I think.
MR. ROEDER: I think you did.
MR. HANNA: Yes.
BY MR. SWEETAPPLE:
Q. So let's go on.
A. April 20th at the top of the page, 1998.
Q. April 20th or April 21st?
MR. HANNA: The page is the 20th. It
starts with the 20th.
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Page 85
BY MR. SWEETAPPLE:
Q. So it says:
"Sweetapple, 4 -21, 8 a.m."
What does that say?
A. "Follow -up calls" -- could have been
for the business -- "CFO" -- that's
Chris -- "to call Sweetapple, re:
filing."
Q. Okay. So CFO means?
A. Chris.
Q. Chris to follow -up. This is a note --
A. "CFO to call Sweetapple, re:
filing."
I don't know. It sounds like it.
Q. What does that refer to?
A. It's from 1998.
Q. What does that refer to?
A. I don't know.
Q. Did you write that down?
A. It looks like my handwriting.
Q. Did he ask you to write it down?
A. It was in 1998. It looks like my
handwriting.
Q. You don't recall --
A. It's very possible.
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Q.
You don't recall
anything about it?
A.
Pardon me?
Pardon me?
Q.
Q.
As you sit here today,
you don't recall
anything about that?
A.
About me writing,
"CFO
to call
Sweetapple,
re: filing," no.
Q.
Okay. What's the
next
thing that you --
A.
It looks like Ed
Jonas,
or it could be
Ed Jones.
"Ed Jonas," or, "Ed Jones, 3:15,
May 18th, Monday."
Q. Ed Jonas, is that an appointment or what
is that?
A. It's either Ed Jones or Ed Jonas.
Q. Okay. Did you write that? Is that your
handwriting?
A. It looks like my handwriting.
Q. And was it an appointment for you or
your husband or you don't know?
A. I don't know.
Q. You don't know what that relates to?
A.
No.
Q.
What's the next thing?
A.
Pardon me?
Q.
what's the next thing?
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It says:
"Sweetapple invoice, 7 -13."
A. "Sweetapple invoice," on Monday,
July 13th.
"Chris to town meeting," same day,
Monday, July 13th.
Q. And what does, "Sweetapple invoice,"
relate to?
A. I don't know.
Q. Do you know if my firm received any
moneys or was Mr. Jonas paid? Do you know?
A. Pardon me?
Q. Do you know if my firm ever received any
moneys?
A. No.
Q. Do you know if Mr. Jonas was paid
moneys?
A. No. You were our attorney at that time.
I would assume that we paid you.
Do you still have your legal files from
that time so you could look up and see if we paid
you and pull out a check that we wrote to you?
Q. I've gone through all my records.
A. Did you find a check from us in your
records?
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Pap 88
Q. No. I found -- and I will be testifying
Monday, but I found a Chris O'Hare number given to
him, but no billing and no time and no invoicing.
So I'll be showing you those at my deposition. I
have absolutely no recollection at all of ever
having met your husband.
A. Pardon me? What was the last thing you
said?
Q. I said my involvement with your husband
was so insignificant to me, because I didn't handle
any legal matters such as a case. I have
absolutely no recollection of even meeting your
husband.
Obviously I have met him and obviously
I've had some communication with him based on his
testimony, because he brought up Mr. Heath King,
and I've represented clients --
I've had family members, I've had
friends -- I've sent over 50 people to Mr. King in
the last -- Dr. King in the last 25 years. So that
tells me I must have had a conversation with him,
but I have absolutely no recollection of him being
in my office, talking to me or doing any legal work
for him.
But you tell me Diane Faulk and that
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tells me that you must have been referred to me,
but at this time, I referred closings and code
violations and things of that nature to Mr. Jonas.
A. It was your firm.
Q. Yes, yes. But you have to understand
just because someone in my firm or me represented
you on --
A. No, Chris was talking to you during that
time. Chris was referring to you during that time.
Q. And so I can't represent the Town of
Gulf Stream with regard to --
A. You represented us against the Town of
Ocean Ridge or involving the Town of Ocean Ridge in
those legal matters and now you're representing
Gulf Stream against Chris.
Q. And you don't think that's proper
legally?
MR. HANNA: I'm going to object to form.
THE WITNESS: I think that is really
crummy. That's really crummy. You're an
attorney. You have a relationship with a
client. You can't go years down the road and
fight against them when you have dealt with
them and worked with them before. That's not
right. But you're the attorney. I'm sure
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you'll find a way out of it or try to,
because that's what you do, right?
BY MR. SWEETAPPLE:
Q. No. I just applied the pretty clear
black letter law, and all you have to do is read
the law and you'll know that just because an
attorney handles a matter for a client doesn't mean
that they are owned by that client for the rest of
their career.
Are you suggesting I couldn't sue you
for running over one of my clients in your car?
MR. HANNA: I'm going to object to form.
BY MR. SWEETAPPLE:
Q. You don't realize I could sue you?
A. I don't know the law. I have no opinion
on that.
Q. Okay. Are you suggesting that what's
goes on in the Town of Gulf Stream has anything to
do with the legal issues that were going on 1998,
anything at all to do with them?
A. I have no opinion on that.
Q. So if this case has absolutely nothing
to do with anything that happened in the Town of
Gulf Stream -- strike that, the Town of Ocean
Ridge --
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A. I said I have no opinion. Now you're
saying, "Oh, so now you're saying" --
You're putting words in my mouth. I
have no opinion.
It seems like it was us and the Town of
Ocean Ridge was on the other side. Now it seems
like you're with the Town of Gulf Stream and you're
on the other side, but coming at us. That's not
right.
Q. Well, the law says you can't do that
where it relates to the same issues that the prior
representation involved, because there's an
advantage.
What in the world does my representation
of the Town of Gulf Stream in 2014 have to do with
what happened in Ocean Ridge in 1998?
MR. HANNA: I'm going to object.
MR. ROEDER: Objection.
THE WITNESS: If you'd had numerous
conversations with Chris, you were his
advocate back in the 1990s. You strategized
with him. You understand how his mind works.
BY MR. SWEETAPPLE:
Q. Okay.
A. You were our -- you were our advocate at
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that time. That gives you intimate knowledge of
how his mind works, what strategies you come up
with. That is not right now to use that possibly
against him at this time.
Q. Okay. You've said --
A. You know full well that. You're sitting
here like oh, you know, oh, I can't imagine.
That's not right and you know that.
Q. No, no. Ma'am, I know the law very well
because I've been practicing for 35 years, and if I
didn't think what I was doing was legal and
ethical, I wouldn't be doing it, okay?
MR. HANNA: Bob, can we take a break?
MR. SWEETAPPLE: Well, I want to
follow -up on one thing.
BY MR. SWEETAPPLE:
Q. You said that I was your advocate, okay,
and now I'm doing something, I guess, that hurt my
early advocacy.
What was I your advocate on?
MR. ROEDER: Objection.
THE WITNESS: You were representing us.
BY MR. SWEETAPPLE:
Q. What did I advocate for you?
MR. ROEDER: Objection.
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BY MR. SWEETAPPLE:
Q. Where did I advocate for you?
MR. ROEDER: She's already answered that
she has no knowledge.
MR. SWEETAPPLE: Okay. Let's take a
break.
VIDEOGRAPHER: The time is 4:22. We're
going off record.
(Recess from 4:22 p.m. to 4:31 p.m.)
VIDEOGRAPHER: The time is 4:31. We are
back on record.
BY MR. SWEETAPPLE:
Q. After the July 13th page, what is the
next item?
I see November 22nd, it says:
"Heath King, 12:15."
Do you know why Heath King is noted in
the tab?
A. Do I know why he's noted?
Q. Yes.
A. No.
Q. Were you aware that your husband was
seeing Heath King?
A. I remember Heath King.
Q. Do you know how many times your husband
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saw Heath
King?
A.
No.
Q.
Did he ever tell you that I recommended
that he see Heath King?
A.
I remember that you recommended Heath
King.
Q.
Okay. And did he tell you what Heath
King specializes
in or why I recommended him?
A.
No.
Q.
And then on December 8th, I see --
A.
You're going forward?
Q.
Yes, going forward, December --
I don't believe there's anything else
noted --
A.
Okay. Let me look over. I didn't
really look
over the rest of this.
Q.
Look and see if there's anything else
that you believe
relates to me or my firm.
A.
No. Okay.
Q.
December 8th, it says Heath King at
noon.
Was that just noting that your husband
had an appointment
for Heath King?
That refers to your husband, right?
Heath King
at noon on the 8th of December, that's
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for your husband, not you, right?
A. I know I saw him with my husband.
Q. Oh, you went to see him as well?
A. A couple of times or two or three times.
Q. So you don't know if that's you, your
husband or both you of --
A. No.
Q. -- sitting here today?
Okay. And then 12/22, it says:
"Heath King, 12:00."
A. Mm -hmm.
Q. Yes?
A. I see that.
Right. How many times did you see Heath
M
King?
A. I don't recall.
Q. Did you like him?
A. I have no opinion.
Q. No opinion. Okay.
All right. 1999. This is Exhibit 2.
Let's keep our exhibits together.
The first notation I see is:
"Heath, 1/12 at 12:00."
Do you know who saw Heath on that date?
A. Which date are you looking at, please?
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Q. 1/12, I see a tab from, I believe, your
husband on the top right -hand corner of mine. It
says:
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day?
"Heath King, 1/12, 12:00."
A. I see H. King.
Q. Right. Okay.
Do you know who saw Dr. King on that
A.
Pardon
me?
Q.
Do you
know who saw Dr.
King on that
A. No. I had two -- I had a four - month -old
and a newborn from January in the home at that
time. We were lucky enough to adopt our two
children, one in August of 1998, one in December of
1998. So this was a very busy time. I was a very
sleep- deprived and having two newborns in the
house -- it was a joy. So I wasn't really focused
too much on Chris and his legal issues.
Q. Well, I also had a newborn in the house
at the same time. She's 16 as well as your kids, I
guess.
A. Both 16.
Q. Mine's 16. It's a great age, isn't it?
On February 9th, it says, 1112:00,
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Heath," again.
A. Mm -hmm, I see that.
Q. And you don't know who that referred to?
A. Pardon me?
Q. You don't know who had an appointment
with Heath on that day either?
A. I don't remember.
Q. Then the next one is March 2. It says,
"Heath," right?
A. I see, "King."
Q. Right. And then March 9th, "Heath,"
April 7th, "Heath "?
A. Wait a minute.
Q. April 15th, "Heath," April 22nd,
"Heath "?
A. I see Dr. King on April 7th.
Q. All I see in your husband's notations on
the copy I have are, "Heath," for 1999.
Are you aware of any meetings in --
A. You mean Chris' notations that are
outside the book?
Q. Chris' notations or --
You're looking at Exhibit 2.
A. It's only my handwriting, I believe, in
my book.
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Page 98
Q. So take some time and look at Exhibit 2
and tell me if there's anything in Exhibit 2 that
refreshes your recollection you believe relates to
me or my firm in 1999.
A. Exhibit 2. You mean of these pages?
Q. Yes. None of the notations your husband
has provided in the one I have mention me or my
firm. They all mention Heath. I want to see if
that's your conclusion as well when you review the
document.
A. I see April 18th. I have at 3:45, "CFO
to Heath." So that would mean Chris to go to Heath
King I'm guessing.
Q. In 1999, you wrote down your husband's
appointments in your calendar, right?
A. If I had two newborns at the house and
it looks like maybe I had an appointment, somebody
with Republic, Larry with Republic in West Palm
Beach at two, it's very possible I would write down
that Chris had to be somewhere at 3:45.
You know, who's gonna watch the
newborns?
You can't take them.
If I had that meeting with Larry, that
would be my -- that would be my call on that, but I
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Page 99
don't really recall.
Q. But it looks like quite often you wrote
your husband's appointments and matters in your
calendar.
A.
I wouldn't say quite often.
Q.
Well, every appointment -- each month
there's an
appointment or two for Heath in this
calendar.
A.
I don't know if that would have been
Chris or
myself. I just don't recall.
Q.
Do you see any references in the year
1999 that
relate to me or my firm?
A.
References to you?
Q.
To me or my firm.
A.
I have not looked through all of the
pages in
this calendar.
Just looking at these pages that were
pulled, I
do not see any reference to you.
(The documents referred to were
thereupon marked Defendant's Exhibit
No. 5 for identification, a copy of
which is attached hereto.)
BY MR. SWEETAPPLE:
Q.
Okay. Let me show you what I'm going to
mark as Exhibit S. This is a composite of over
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Page 100
1,600 different public records requests that your
husband has either filed or caused to be filed --
let me rephrase.
This is just the 2014 requests that your
husband has filed of over 1,600 public records
requests that your husband either individually or
through agents or fictitious names has served on
the Town of Gulf Stream. So I want you to take a
look at this exhibit.
A. Do I have to read all of them? Are we
going to take the time for me to read each request
in detail?
Q. Well, I want to go through --
Let's see what your understanding is and
we'll find out.
A. So are we going to start at the top
then?
MR. ROEDER: Is this an exhibit?
THE WITNESS: Do you have a copy of this
exhibit?
MR. ROEDER: We just got it right here.
BY MR. SWEETAPPLE:
Q. Let me rephrase.
Of the 1,600 requests that have been
filed by what we allege is a group of people acting
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Page 101
in concert, approximately 800 we believe have been
filed by your husband and his direct agents or by
him under pseudonyms.
Are you aware that your husband is
filing public records requests under pseudonyms?
A. No.
MR. HANNA: I'm going to object to the
question.
BY MR. SWEETAPPLE:
Q. Have you ever looked at any public
records requests that your husband has filed with
the Town of Gulf Stream?
A. No.
Q. Have you ever discussed with your
husband that you thought what Joel Chandler was
doing was sleazy?
A. Have I ever discussed --
Q. With your husband
A. -- with my husband
Q. -- that what you thought Joel Chandler
was doing to towns in Florida was sleazy.
A. I don't recall whether it was from Chris
or the Coastal Star that I heard he was requesting
these records from all these different towns.
Q. That Chandler was?
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Page 102
A. That Joel Chandler was.
Q. Did you ever tell your husband that you
thought what Joel Chandler was doing was sleazy?
A. I may have.
Q. Prior to today, were you aware that your
husband had filed hundreds and hundreds and
hundreds of public records requests to the Town of
Gulf Stream?
A. I don't remember a number that was
mentioned in the Coastal Star, but in that article,
it was mentioned that he'd filed a lot.
Q. That your husband had?
A. Yeah.
Q. Have you ever asked him why he's doing
that?
A. I support him in that. Whatever he
wants to do, he's doing it because he feels he has
a need to access those records.
Q. Has he ever told you -- have you ever
discussed with him what his needs are for these
records?
A. Not specifically, no.
Q. Have you ever looked at the things he's
asked for in these public records?
A. No.
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Page 103
Q. Are you aware that with regard to the
records that are the subject of this case today,
they were made available to your husband in
December of 2013 and he didn't pick them up for
three months?
MR. HANNA: I'm going to object to form.
BY MR. SWEETAPPLE:
Q. Are you aware of any of the facts
regarding the documents in this case?
MR. HANNA: Objection.
THE WITNESS: I'm aware from the article
in the Coastal Star that you, Bob Sweetapple,
are working with the Town of Gulf Stream and
threatening my husband and my family --
trying to destroy my family and threatening
my husband with a RICO action, with an
organized crime action because he is
requesting public records from the Town.
That's what I understand, that you used to
work for us, "Oh, that Bob Sweetapple? That
Bob Sweetapple ?"
Yeah, Bob Sweetapple. Bob Sweetapple's
now working with the Town of Gulf Stream and
he's threatening my husband who used to --
and Bob Sweetapple used to work for us.
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That's what I understand.
BY MR. SWEETAPPLE:
Q. Okay. And did I work with you with
regard to any issues concerning the filing of
hundreds of public records requests to Gulf Stream
as part of an organization that filed thousands of
public records requests throughout the state of
Florida in order to shakedown governments for
money?
MR. ROEDER: Objection.
MR. HANNA: Object to the form of the
question.
THE WITNESS: That sounds like it's some
confusing question.
What is the question you're asking me?
BY MR. SWEETAPPLE:
Q. I'm asking it's your position that your
husband was asking for these public records because
he had some use and need for them?
A. I assume he did, yes. I was not
involved in the public records request. If he
needs the public records, then he asked for them.
They are public information. This is the public.
Q. And are you aware of any specific public
records that your husband wanted and needed? Is
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there any document he told you he needed from the
Town of Gulf Stream?
A. Not specifically, no.
Q. Can you tell me any document that he
told you he was requesting?
MR. ROEDER: Asked and answered.
BY MR. SWEETAPPLE:
Q. Can you tell me any document --
A. What did you just say?
Q. -- that your husband specifically told
you he had requested from the Town of Gulf Stream?
A. Any document that he requested?
I don't recall.
Q. Did you ever discuss with him whether or
not you thought what he was doing was sleazy with
regard to public records requests?
A. I don't recall that.
Q. Did you ever discuss with him if he was
working with Mr. Chandler and the O'Boyle law firm
to file hundreds and hundreds and hundreds of
public records requests in order to close down and
pressure the Town of Gulf Stream?
MR. HANNA: Object to form.
MR. ROEDER: Objection.
THE WITNESS: No, and it sounds like
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you're preparing material for this RICO
action that you're working with the Town of
Gulf Stream against my husband on. That's
what it sounds like, these questions you're
asking. You're like trying to form some
basis so that you can file a lawsuit against
my husband when you've worked for us before.
BY MR. SWEETAPPLE:
Q. With regard to a code violation case
you're saying in 1998.
A. With regard to legal action against the
Town of Ocean Ridge. It was the Town of Ocean
Ridge and this neighbor against us, and now you're
working for the public. You're working for the
Town of Gulf Stream against us, so it's the
opposite. It's not right. There are lots of
attorneys the Town of Gulf Stream could hire. They
should just go hire another attorney. You're not
the only fish in the sea.
Q. You're going to have a chance to argue
that legal proposition that your attorneys are
advancing in court, okay?
A. That's fine. You shouldn't be there.
You should refer this to someone else.
MR. ROEDER: Objection. You know, she
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was giving you an answer. She wasn't
arguing.
MR. SWEETAPPLE: Let's go forward.
MR. ROEDER: If she was arguing, then
everything that you've been doing has been
argument. Let's go forward with your
question.
MR. SWEETAPPLE: We're going to have the
judge decide whether you're right on the law
or your attorney's right on the law or --
MR. ROEDER: Please ask a question.
MR. SWEETAPPLE: -- I'm right on the
law.
MR. ROEDER: Please ask your question,
counsel.
THE WITNESS: I only have my opinion.
That's all I have. I just have my opinion.
You've worked for us and now you're working
against us. That's my opinion.
MR. HANNA: Okay.
BY MR. SWEETAPPLE:
Q. And what I would like to know is prior
to today, how many public records did you think
your husband -- public records requests did you
think your husband had made with the Town of
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A. I don't know.
Q. Did you think he made more than ten?
MR. ROEDER: Asked and answered. She
said she didn't know.
BY MR. SWEETAPPLE:
Q. Did you have any idea at all?
A. I don't know.
Q. Did you have any idea at all?
A. No, I don't know.
MR. ROEDER: How many different ways can
she answer you, counsel?
MR. SWEETAPPLE: Well, I can keep
probing until I get some kind of --
I'm going to show her this to refresh
her recollection.
THE WITNESS: That sounds like you're
really badgering me. You're really just
push, push, pushing like that.
What is the point? Why do you need to
know? What's the point?
I don't know how many public records
requests he filed. You just showed me this.
Obviously you know, so why are you asking me
how many he filed?
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You know how many he filed, because
you're working with the Town of Gulf Stream
against him, and you worked for us before and
that's not right.
BY MR. SWEETAPPLE:
Q. Well, that's what you keep saying and
we're gonna have a hearing on that.
A. That's why I'm here. The Town of
Gulf Stream should go hire another attorney instead
of you. There's plenty of people they could hire.
Q. That's what you believe.
A. That's why I'm here, to give my beliefs
and my opinions right now right here.
Q. No. You're here to testify to facts,
and so far your knowledge of facts is all we're
concerned about. Your legal opinion and your
beliefs are of no matter here.
MR. HANNA: All right. How about asking
a question?
THE WITNESS: Why don't you just ask me
a question, then I can answer your question.
You're just -- you're really -- I'm really
getting upset with this. This doesn't have
to do with Bob Sweetapple.
Did Bob Sweetapple work for us before?
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Yes, he did. That's the truth, and are
you working against us now?
Yes, you are. That's the truth. You're
working against us and you worked for us
before. That is not right. I don't know
what you're getting at now, but it's not
having to do with whether you worked for us
before, and you did. You did a good job for
us, and now you're pursuing us, and you have
intimate knowledge of what Chris' strategic
ideas are and you've spoken with him before.
BY MR. SWEETAPPLE:
Q. I have his knowledge with regard to
making hundreds of public records requests?
A. No, but you worked for us with the Town
of Ocean Ridge. That's not right.
MR. HANNA: Ask a question --
THE WITNESS: And now you're working
against us.
MR. HANNA: -- and answer the question.
BY MR. SWEETAPPLE:
Q. Let me be clear to you. Part of this
deposition is dealing with your position that I am
not authorized to represent the Town, okay?
I am now asking you questions that deal
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with the defense of the case your husband has
brought and that deal with counterclaims that are
going to be brought against your husband. So yes,
I intend and I believe the Court is going to
summarily throw out your nonsense argument --
MR. ROEDER: Objection.
MR. SWEETAPPLE: -- that what I did in
1998 prevents me.
MR. ROEDER: This has gone too far.
Are you going to keep pontificating
here?
THE WITNESS: You know, are you asking
me a question or are you just badgering me
and just, you know, trying to beat me over
the head with stuff?
Come on.
MR. HANNA: Ask a question.
MR. SWEETAPPLE: Thank you.
MR. HANNA: Answer the question.
BY MR. SWEETAPPLE:
Q. Are you aware that your husband on
November 13, 2014 submitted a public records
request under the name of Americo Vespuchi?
A. No.
Q. What about Wyatt Burp on November 13th,
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also?
A. No.
Q. Are you aware he submitted one under the
name Wyatt Burp?
A. No.
Q. What about Prigs Hypocrites?
A. No.
Q. What about Patrick Henry?
A. No.
Q. Do you have any idea why your husband
has submitted the public records requests that are
contained just in 2014 --
A. No.
Q. -- in Exhibit 5?
Pardon?
A. I have no idea. This is his business.
He needs it. If he feels like he needs it, the
Government has a right to give it to us. If he
requests a record from a Government agency, then
the Government agency needs to produce the record
and give it to him.
This is the legal way of the system,
correct? This is transparency?
It's not against the law to request
public records. You could request a public record.
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any --
Q. You're giving me your legal opinion
MR. HANNA: All right --
THE WITNESS: I'm not an attorney, Bob.
You're just trying to just, you know, poke,
poke, poke.
SWEETAPPLE:
Q. I'm asking you --
A. It's not right.
Q. I'm asking you whether or not you have
First of all, you told me you have no
idea how many public records requests your
husband's made.
Now I've asked you if you have any idea
why he's made them, and your answer is no, right?
A. (Witness moves head from side to side.)
Q. And your answer is further that you
believe he has the right to make as many public
records requests for whatever reason he wants to
make them.
MR. ROEDER: Okay. Is there a question
here somewhere?
THE WITNESS: Is there a question? Are
you asking me --
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Page 114
Q. Yes.
A. -- can he make as many as he'd like?
Q. You have no idea how many public records
requests your husband has made?
MR. ROEDER: Asked and answered.
BY MR. SWEETAPPLE:
Q. Are you aware that on September 29th, a
Sunday, 213, 2013, in four hours your husband filed
40 public records requests just to the Town of
Gulf Stream?
A. No.
Q. Do you know why he did that?
A. Do I know why he filed those record
requests on that date?
No.
Q. Have you ever looked at any public
records request your husband has filed?
A. No.
Q. Let's go through some of them to see if
we can figure out why he made them.
A. I'm assuming this is so that you can get
ammunition for the lawsuit that you'll be filing
against Chris.
All right. Let's go through them.
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That's fine, Mr. Sweetapple.
Q. Are you aware that your husband has
filed approximately 24 lawsuits against the Town of
Gulf Stream?
A. I didn't know the exact number.
Has he filed 24 lawsuits against the
Town?
Q. Well, how many do you believe he's
filed?
A. I don't know.
Q. Can you tell me the basis for one of the
lawsuits he filed?
A. I'm not positive, but I know he was
upset about a police officer coming by and having
us move trees. He had planted some trees near the
road and the police officer came by and told him
that he had to remove the trees, that they were in
the right -of -way, in the swale area.
Q. Any other lawsuits you're aware that
he's filed? Any other things that are so important
that --
A. Not specifically.
Q. Filing a lawsuit's pretty important,
right, pretty important step? Pretty major,
wouldn't you say?
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Page 116
A. I have no opinion on that. Depends.
Q. If your husband has filed 24 lawsuits
just against the Town of Gulf Stream, can you tell
me any other things besides the tree and the
policeman that you believe he's concerned about?
A. No.
Q. You have no idea of any other topic that
he's litigating over?
A. I don't know.
Q. Are you aware that he's filed a lawsuit
with Mr. O'Boyle, Martin O'Boyle, as the plaintiff?
A. No.
Q. Are you aware that he is represented by
the so- called O'Boyle Law Firm?
MR. HANNA: Objection.
MR. ROEDER: Objection.
MR. SWEETAPPLE: What's the objection?
MR. ROEDER: So- called.
MR. HANNA: Mischaracterization.
BY MR. SWEETAPPLE:
Q. Are you aware that Mr. O'Hare is
represented in numerous cases and has been by a law
firm that calls itself The O'Boyle Law Firm?
A. No.
Q. You didn't know that?
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A. I didn't know the law firm was called
The O'Boyle Law Firm. I know the name Jonathan
O'Boyle.
Q. Did you know Jonathan O'Boyle was
representing your husband?
A. No.
Q. Why do you know the name Jonathan
8 1 O'Boyle?
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Page 117
A. Because I've heard Chris talk to him on
the phone, "Jonathan O'Boyle this, Jonathan O'Boyle
that."
Q. Is Jonathan O'Boyle his attorney?
A. I don't know.
Q. What has your husband told you about
Jonathan O'Boyle?
A. I think I met him at a party.
Q. Has he told you that he's doing any
legal work for him?
A. That what?
Q. That Jonathan is doing any legal work
for your husband.
A. No specifics, no.
Q. But generally, do you know that Jonathan
O'Boyle is representing your husband?
A. I don't know that he's representing him
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on any specific cases.
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Q.
Do you know if The O'Boyle Law Firm is
3
representing
your husband on any specific cases?
4
A.
I just said that. No, I didn't know
5
that.
6
Q.
Do you know whether or not The O'Boyle
7
Law Firm
has filed hundreds and hundreds of public
8
records requests
on governments and state agents
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throughout
the state of Florida?
10
A.
Do I know that?
11
Q.
Mm -hmm.
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A.
No.
13
Q.
No one's made you aware of that?
14
A.
(Witness moves head from side to side.)
15
Q.
Do you know if Jonathan O'Boyle is a
16
member of
the Florida Bar?
17
A.
No.
18
Q.
How many times has your husband called
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Jonathan
O'Boyle to your knowledge or told you he's
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talked to
Jonathan O'Boyle?
21
A.
I don't know.
22
Q.
Does your husband communicate by e -mail
23
with Mr.
O'Boyle?
24
A.
I don't know.
25
Q.
Does he communicate by text?
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A. I don't know.
Q. How many times have you ever met
Mr. Chandler?
A. I think only once. I'm trying to think.
I think I've seen him somewhere before. I know I
met him at a party at his -- an election party at
his father's house.
MR. ROEDER: He's talking about
Chandler.
BY MR. SWEETAPPLE:
Q. Mr. Chandler.
A. Oh, Mr. Chandler. I thought you said
Jonathan O'Boyle.
Mr. Chandler?
Just that one time.
Q. And you met Jonathan O'Boyle one time?
A. Yes.
Q. At his father's house?
A. (Witness moves head up and down.)
Q. At Martin's house?
A. At who's house?
Q. At Martin O'Boyle's house?
A. Correct.
Q. Did Jonathan live at Martin's house?
A. I don't know.
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Page 120
Q. And are you aware of whether or not your
husband has placed any signs or drawings on a boat
in a canal in Gulf Stream?
A. Yes.
Q. What has he done?
A. Pardon me?
Q. What do you understand he's done?
A. That he parked a boat outside the
mayor's house with a sign on it.
Q. What'd the sign say?
A. I think it said something hypocrite --
something, something hypocrite.
Q. So if I go through all of these public
records requests -- and why don't you turn with me.
Let's just turn the pages. These are all the
public records requests that your husband has asked
the employees at the Town of Gulf Stream to --
MR. ROEDER: Objection.
THE WITNESS: These are all legal public
record requests.
MR. ROEDER: Based on your previous
questions, that is not a correct
recollection.
BY MR. SWEETAPPLE:
Q. Strike that.
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A. Do I recall?
No, I haven't seen this.
MR. ROEDER: Don't answer the question
because he hasn't asked a proper question.
BY MR. SWEETAPPLE:
Q. Let me rephrase it.
A. What is the question?
Q. When you go through all of the requests
in here that are Mr. O'Hare, which I marked in
yellow -- I'm going to give you mine -- in
yellow --
MR. ROEDER
yellow.
BY MR. SWEETAPPLE:
Hers aren't marked in
Q. I'm gonna give you mine to look at.
MR. SWEETAPPLE: Oh, you haven't gone
all the way through it?
SWEETAPPLE:
Q. Never mind. We haven't gone through all
of them. I'm not going to have you go through and
look at every one that's Mr. O'Hare.
A. What is the question?
Q. If I show you specific public records
requests that your husband made, it's not going to
help refresh your recollection at all, because you
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have no idea why he's doing it, right?
MR. HANNA: Objection.
Mischaracterize --
THE WITNESS: Do I have an idea why he's
doing it?
MR. ROEDER: She's answered that
question.
THE WITNESS: He needs it. It's a
public record. You can have a public record.
He feels that the Town of Gulf Stream is
not applying the law equally to him like it
is to the other residents and the law's not
spelled out. He needs public records.
BY MR. SWEETAPPLE:
Q. So you believe that the public records
he's asked for deal with the application of the law
to him?
A. I don't know.
Q. Well, is there any other topic that he's
ever expressed he needs a public record for?
A. I don't know.
I'm tired. I'm tired of this. I've
said what I came to say.
Do you have more questions for me, a lot
more questions for me?
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Q. I'm going to go through your --
We're here because of your husband's
motion initially and I do have his motion here. I
want to go through it. So I'm going to --
It's 5:00. If you want to break, we
can. I'm happy to do that.
A. Let's go through the motion. Finish up.
Q. I'm trying to finish up as quickly as I
can.
A. I don't know why the Town of Gulf Stream
just can't go hire someone else. You're just not
the only attorney. There are lots of other
attorneys.
Q. Because they don't have to.
A. You've worked for us before. Have them
go hire someone that hasn't worked for us before.
Q. First of all, they don't legally have
to. That's why.
MR. HANNA: Ask a question.
MR. ROEDER: Ask a question, please.
BY MR. SWEETAPPLE:
Q. Are you aware that your husband's filed
cases in federal court?
A. Yes.
Q. And what did that case involve? Do you
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Page 124
know?
A.
Specifically, I don't know.
Q.
It says in paragraph 3:
"Attorney Robert Sweetapple
represented Plaintiff in 1998" --
Plaintiff is your husband -- "when
Plaintiff was involved in several
disputes in the Town of Ocean Ridge,
hereinafter Ocean Ridge, individual
Ocean Ridge officials and personnel and
residents."
Which individual Ocean Ridge officials
did I represent your husband concerning?
A.
I don't know.
Q.
And which personnel or residents did I
represent
your husband concerning?
A.
I don't know.
Q.
It says that the prior matters have
similar underpinnings to the current litigation
with Gulf
Stream.
What are the underpinnings that are the
same in 1998 with the current case?
A.
I don't know.
Q.
It says that Ocean Ridge is very similar
to Gulf Stream. They are geographically separated
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by a small trailer park.
What difference does it make if
Gulf Stream and Ocean Ridge are similar towns?
They're not the same town, are they?
MR. HANNA: I'm going to object.
BY MR. SWEETAPPLE:
Q. Strike that.
A. What is the question?
Q. I never represented you or your husband
with anything involving the Town of Gulf Stream,
did I?
A.
With the Town of Gulf Stream?
Q.
Right. I've never represented you with
regard to
anything with the Town of Gulf Stream?
A.
I don't know.
Q.
I've never represented you with regard
to any issue
concerning public records requests,
right?
A.
I don't know. There may have been.
When you
were representing us with Ocean Ridge, you
may have
requested records from Ocean Ridge at that
time. Who
knows?
Q.
Do you have any evidence or facts of
that or you're
just saying may?
A.
Well, you're an attorney. That sounds
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like it'd be something an attorney would do.
You're representing us, "Oh, you might want to
call -- for public records, you might want to call
Ocean Ridge and get some public records to verify
something about our apartment building." I don't
know.
Q. I have no records that show I ever filed
any lawsuits, public records request or other legal
documents on your behalf. I have nothing that I've
showed that I signed on your behalf.
A. Do you have a file we can look at from
when you were employed by us?
Q. No. I have nothing. I've told you what
I have, which is one thing that shows a matter was
opened and it shows no billing and no time, and
I've seen documents that show Mr. Jonas was
involved for a week and I made --
MR. HANNA: All right.
MR. ROEDER: Can we please ask
questions?
You're pontificating again.
BY MR. SWEETAPPLE:
Q. The various matters included a lawsuit
by a neighboring property owner.
Your husband has sworn that I
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represented him in a lawsuit by a neighboring
property owner against Ocean Ridge and Plaintiff.
Are you aware of me representing your
husband in any lawsuit involving a neighboring
property owner --
A. In Ocean Ridge?
Q. -- against Ocean Ridge?
A. Well, that was probably the neighbor
that I told you about that claimed we blocked his
ocean breeze with our roof.
Q. And there was a lawsuit?
A. That was a legal issue then. I think
there were a few legal issues. I just don't
remember the specifics. I had two newborns. I was
dealing with two birth mothers, the attorneys,
setting up the nursery. You know, I was dealing
with matters of the heart. My mind was not on the
legal issues. I let Chris handle that. He had the
communications with you.
Q. Are you aware of any -- has your husband
ever told you that I represented him in a lawsuit
by a neighboring property owner?
A. I don't recall. Many times he would
say, " Sweetapple this. Sweetapple that. He said
this. He called. I called."
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Page 128
You were representing us against the
Town of ocean Ridge at that time.
Q. It says:
"Plaintiff was treated by the
therapist recommended by Attorney
Sweetapple. Plaintiff believes that
Attorney Sweetapple and the therapist may
have shared protected health information
regarding his treatment."
Did your husband ever tell you that he
thought that I had talked to the therapist about
A. I'm getting uncomfortable with all of
this, because you referred us to the therapist and
now you're on the other side and you're asking us
questions about the therapist and what went on
there. So we confided in you and we hired you as
our attorney and we paid you and you did work for
us and you recommended this therapist, and now
you're asking me questions about the therapist and
what went on there or that type of thing?
You know, what happened to some sort of
confidential relationship between a therapist and
his clients or an attorney and his clients, because
you were our attorney.
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Don't we have any rights there as far as
protection, and you're asking me these questions
now from the other side?
That's awful.
Q. I'm reading to you from a sworn motion
that your husband has filed as part of a motion in
a lawsuit that he has filed.
A. What is the question for me? What is
the question for me?
Q. What your husband has sworn to in a
motion he has filed in a lawsuit he has filed --
A. All right. What is the question for me?
Q. -- that he has made allegations against
me is this:
"Plaintiff believes that Attorney
Sweetapple and the therapist may have
shared protected health information
regarding his treatment."
And what I asked you is has your husband
ever said to you that he believes that I talked to
Heath King about him? Did he ever complain to you
that he thought that?
A. Did he complain to me that he thought
you had talked to Heath King?
M
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Q. Do you have any indication from anyone
that I ever talked to Heath King about your
husband?
A. How would I know that?
You referred Heath King to us.
How would I know what you discussed with
Heath King or what you discussed with Chris?
I wasn't there.
How would I know that?
Q. Your husband has sworn to it and I want
to find out if you know anything about it.
MR. HANNA: She's already answered the
question.
THE WITNESS: This is all such
confidential information. It's not right.
You're coming at us -- you know, you're
coming at us with a sword and you're the one
that referred us to the guy. It's not right.
BY MR. SWEETAPPLE:
Q. I've never spoken to Heath King about
your husband's treatment and I'm not talking to you
about any conversations regarding your husband's
treatment. I don't even remember meeting your
husband. So you can rest assured that none of that
occurred, even though it appears to have occurred
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in your husband's mind, okay?
MR. HANNA: All right. Please ask a
question.
BY MR. SWEETAPPLE:
Q. So you keep getting worked up and
self- righteous, but --
MR. HANNA: And you're doing the same
thing.
THE WITNESS: This should have been over
a long time ago. It's after 5:00. We were
here at two.
BY MR. SWEETAPPLE:
Q. Ma'am, your husband has 24 lawsuits and
800 public records requests. This isn't going to
be over a long time ago, let me assure you of that.
MR. HANNA: All right. Ask a question.
MR. ROEDER: You're intimidating the
witness. Please.
THE WITNESS: Yeah, what is that?
MR. SWEETAPPLE: This is silly. Your
husband brings all these lawsuits.
It should be over? I've been here one
hour, one and a half hours?
MR. ROEDER: Two and a half hours.
MR. HANNA: Please ask the question.
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THE WITNESS: He's handling it. I
support him in that.
BY MR. SWEETAPPLE:
Q. Good. Well, let's go through that. I
want to know what you know. We've gone through
your calendar.
MR. ROEDER: She's already told you she
doesn't know anything about that document.
MR. SWEETAPPLE: Okay. Well, let's keep
going. I've got his sworn pleading. Let's
see what she knows about it. She says she
was one of the clients. I advocated for her.
I represented her. Everything was her.
THE WITNESS: You're yelling at me.
Stop it.
MR. SWEETAPPLE: I mean, I've heard you
yell your position.
MR. HANNA: Ask a question.
MR. SWEETAPPLE: I'm going to.
MR. ROEDER: Both counsels and the
witness are asking you to ask a question.
Please get to it.
BY MR. SWEETAPPLE:
Q. It says here --
Do you believe that the current
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Page 133
representation in this case is substantially
related to the prior representation?
A. I don't know what that means.
Q. Is there anything about this case, the
pending case, that you believe relates to
representation in 1998?
A. I don't know.
Q. Are you aware of anything that you
believe is related to the prior representation?
A. I feel that the -- when we had those
legal issues before and you represented us and you
advocated for us, that it was us against the Town
of Ocean Ridge, and I've said this before and you
keep getting back to it.
Now you're working with the Town of
Gulf Stream, and you've had numerous conversations
with Chris in the past and you were our attorney,
and now you're representing the Town of Gulf Stream
against us. That's what I know. It seems like
it's the same. I don't know about the specifics,
but it seems very much the same.
Q. Was Martin O'Boyle involved in the prior
Ocean Ridge matter?
A. No.
Q. Was Jonathan O'Boyle involved in the
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prior Ocean Ridge matter?
A. No.
Q. Was a company by the name of Citizens
Awareness Foundation involved in the 1998
representation?
A. I don't know.
Q. Was a law firm by the name of The
O'Boyle Law Firm involved in 1998?
A. I don't know.
Q. Was Citizens for Responsible Government
involved in the 1998 --
A. I don't know.
Q. -- representation?
Was there any mention of a racketeering
influenced corrupt organization in the 1998
representation?
A. Not that I know of.
Q. Was there any mention of abuse of
process in the 1998 litigation?
MR. HANNA: I'm going to object to form.
There's no allegation of abuse of process
pending in this case. If you want to -- when
you file your lawsuit and your counterclaim,
have at it, but right now there's nothing
involving that.
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 134
Page 135
1 BY MR. SWEETAPPLE:
2 Q. I just want to know if in 1998, was
3 there any reference -- was there any reference or
4 mention of abuse of process in 1998?
5 A. Not that I recall.
6 You're making Chris out to be -- you're
7 threatening him with some sort of organized crime
8 activity, organized crime for asking for public
9 records when he's not been treated fairly, and
10 you're treating him like a criminal?
11 That's not right.
12 Q. I think the Town voted to bring a civil
13 action against him for violation of --
14 A. That's RICO, organized crime, correct?
15 Yes. Organized crime for asking for
16 public records.
17 Q. Well, do you think your husband actually
18 had a legitimate reason for asking for 800 public
19 records?
20 A. I assume he did if he asked for them,
21 and he has every right -- every person has every
22 right to records by the Government. It's not some
23 sort of illegal organized crime activity.
24 Q. Well, that's what a jury's going to
25 decide I suggest.
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MR. ROEDER: Please. Ask your
questions.
BY MR. SWEETAPPLE:
Q. Are you aware that the Florida Bar
prohibits representing another person in the same
or a substantially related matter in which that
person's interests are materially adverse?
What about the current case --
A. What is the question?
You just asked a question and then you
started to say something else.
Q. That what the bar rules prohibit is
representing another person in the same --
A. Are you reading that?
Q. Yes, a same or a substantially related
matter.
What about the current case that I'm
handling is the same or substantially related to
what happened in 1998?
A. I don't know.
Q. Has your husband ever complained to you
that he believed that the Town should have approved
an application for a solar roof?
A. He mentioned some sort of sandwich panel
to conserve electricity.
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Page 137
Q. Did he tell you that that application
was turned down by the Town?
A. I don't know. I don't know.
Q. Did he ever tell you that he was going
to file public records requests and harass the Town
until he got his solar roof?
MR. HANNA: I'm going to object.
MR. ROEDER: Object.
THE WITNESS: He never said he was going
to harass the Town.
BY MR. SWEETAPPLE:
Q. Do you believe he's harassing the Town?
MR. ROEDER: Object.
THE WITNESS: No. He needs what he
needs. You're just putting words in my mouth
or trying to. You're being really nasty with
this. This is not right.
BY MR. SWEETAPPLE:
Q. Ma'am, what your husband's doing is
clearly not right, but you can go ahead and talk
all you want about what's right.
MR. HANNA: All right. Enough speech
making.
MR. ROEDER: This is going to end pretty
quick.
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BY MR. SWEETAPPLE:
Q. Now, Mrs. O'Hare, are you aware that
your husband filed a suit with regard to the roof?
A. To a solar roof?
Q. Yes. He's filed a lawsuit over that.
A. No.
Q. Do you have any idea what the terms of
his employment are with the O'Boyle firm? Is he
paying the O'Boyle fees, The O'Boyle Law Firm fees?
MR. HANNA: All right. I'm going to
object and instruct the witness not to
answer.
MR. SWEETAPPLE: He's got a claim for
fees in cases with The O'Boyle Law Firm. I'd
like to know if she knows --
MR. HANNA: Do you want to admit
entitlement here?
Then we can get into the amount of
attorney's fees.
MR. SWEETAPPLE: I didn't ask the
amount. I said whether or not he has an
agreement to pay fees.
MR. ROEDER: The O'Boyle Law Firm is not
an attorney represented -- they've not made
an appearance on this particular case.
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 138
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Page 139
MR. SWEETAPPLE: I understand that.
MR. ROEDER: So why are you asking about
this?
It's not pertinent to this deposition.
MR. SWEETAPPLE: Because you've
indicated you're concerned about me coming
into other cases.
BY MR. SWEETAPPLE:
Q. Are you aware whether or not your
husband has any written fee agreements with The
O'Boyle Law Firm?
A. No.
Q. Do you know if he's being represented on
a contingency basis with The O'Boyle Law Firm?
A. No.
Q. Do you know if Jonathan O'Boyle is
appearing pro hac vice for your husband --
A. Do I know if he's what?
Q. Do you know if Jonathan O'Boyle is
appearing in cases pro hac vice --
Do you know what that is?
A. What was the last word?
MR. ROEDER: You may need to explain
that, please.
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BY MR. SWEETAPPLE:
Q. Has your husband ever told you that
Jonathan O'Boyle is appearing for him as an
out -of -state attorney in cases?
A. No.
Q. Do you know how many cases Jonathan
O'Boyle has applied to appear pro hac vice in the
state of Florida?
A. Do I know how many cases some attorney
has applied for for what?
Q. When you talked with Jonathan O'Boyle --
A. Did you just ask a question?
Q. Let me rephrase it. Let me rephrase it.
You don't know that Jonathan O'Boyle is
representing your husband as an out -of -state
attorney?
�kINS
Q. Okay. Do you know who Kelly Avery is?
A. Who?
Q. Kelly Avery.
A. What's the last name?
Q. Avery?
A. A- V- E -R -Y?
Q. Yes.
A. No.
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Debra Duran & Associates
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Page 141
Q.
Do you know if your husband has ever
submitted
requests under the name Billy Trasher?
A.
No.
Q.
Bobby Gangrene?
A.
What is the question?
Q.
Do you know if your husband has ever
submitted
public records requests under the name
Billy Trasher?
A.
No.
Q.
What about Bobby Gangrene?
A.
No.
Q.
Do you know if he has an address that
he's created called billytrasher @gmail.com?
A.
No.
Q.
Do you know if he has an address that
he's created
called bobbygangrene @gmail.com?
A.
No.
Q.
What about Gonna White? Are you aware
whether or not he's using the name Gonna White?
A.
No.
Q.
Are you aware whether or not he's
created an e -mail address gonnawhite @gmail.com?
A.
No.
Q.
What about Scotty Morgin, M- O- R- G -I -N?
Are you aware
--
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Page 142
A. No.
Q. Do you know why a public records request
was filed in September 30 of this year on behalf of
Bobby Gangrene:
"Please provide the five most recent
travel reimbursements to Kelly Avery "?
Do you have any idea why that was
submitted?
A. No.
Q. Do you know that when you submit a
request for documents, that under certain
circumstances, you have to pay for the cost of
photocopying?
A. No.
Q. Has your husband ever told you that in
order to circumvent paying the cost of copying,
that he often submits requests using fake names?
MR. ROEDER: Objection.
MR. HANNA: Mischaracterization.
How about the fact that they don't give
him the public records when he requested them
himself and February 24th they banned giving
him any more public records requests?
THE WITNESS: What is the question?
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Page 143
BY MR. SWEETAPPLE:
Q. Mrs. O'Hare, do you want to answer that
or do you want to have Mr. O'Hare's attorney answer
the question, which appears to be an admission that
he's doing this?
MR. ROEDER: Objection. You don't need
to answer that. Inappropriate question.
BY MR. SWEETAPPLE:
Q. Do you know whether or not your husband
is using fictitious names to make public records
requests?
A. No.
Q. He's never told you that?
A. That he's using fictitious names --
Q. Fake names.
A. No.
Q. So you don't know why he's doing it if
he's doing it?
MR. ROEDER: She just told you she
didn't know that he was doing it.
BY MR. SWEETAPPLE:
Q. So, therefore, you do not know why,
right?
A.
(Witness
moves head
from side to
side.)
Q.
I could
conclude you
do not know
why
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he's doing it?
A. You could conclude that.
Q. And when did your husband stop going to
Dr. King?
A. I don't know.
MR. SWEETAPPLE: I don't have any
further questions at this time.
CROSS EXAMINATION
BY MR. HANNA:
Q. I just have a brief follow -up, very
brief.
Back in 1998, you mentioned that there
was -- you were going through an adoption process.
A. We adopted two children. My son was
born in August and my daughter was born in
December. We adopted my son 36 hours old. We
adopted my daughter 24 hours old. So we had two
brand new babies in the house.
Q. So that was August, 1998 and December,
1998?
A. Correct.
Q. Was there a lot of work that had to be
done to finalize the adoptions?
A. It was a very busy year.
Q. When did you start? When did you start
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Page 145
with the adoption process?
A. I think it was about ten months
before -- well, really it began quite a few years
beforehand, went through a number of different
avenues and then we found an attorney and were
paired with the birth mothers.
Q. And when you were paired with the birth
mothers, this was during early in their
pregnancies?
A. It was different for each of them.
Q. And your primary focus in 1998, was it
on the adoptions and the babies?
A. Oh, definitely.
Q. Were you a little nervous that the birth
mothers might back out?
A. Always, because in Florida, the birth
mothers are really in the driver's seat, so it's
not finalized until it's finalized, but it was a
joyous year.
MR. HANNA: All right. I don't have
anything further.
MR. SWEETAPPLE: All right. Let's make
sure we have all the exhibits, I think 1
through 5.
MR. ROEDER: Did you get this labeled?
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MR. SWEETAPPLE: She'll have to label
that. That was 5.
THE WITNESS: What about this?
This looks like a duplicate.
MR. SWEETAPPLE: Yeah, if you'll give me
those back that aren't tabbed. Those will
stay with the depo.
VIDEOGRAPHER: The time is 5:24. This
marks the end of the deposition.
MR. ROEDER: Do you want her to waive?
MR. HANNA: Read, read.
MR. ROEDER: We'll read.
COURT REPORTER: Would you like the
transcript on this one?
MR. SWEETAPPLE: Please.
(Thereupon, the taking of the deposition
was concluded.)
(Reading and signing not waived.)
DEPONENT
Notary Public
My Commission Expires:
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Page 146
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CERTIFICATE OF OATH
STATE OF FLORIDA :
COUNTY OF PALM BEACH:
I, the undersigned authority, certify
that SHELLEY CHILDERS O'HARE personally
appeared before me and was duly sworn.
WITNESS my hand and official seal this
4th day of January, 2015.
/ X(�' 94L
Mia Sohn, RPR
Notary Public - State of
Florida
My Commission No.: FF017720
Expires: Aug. 30, 2017
Debra Duran & Associates
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REPORTER'S DEPOSITION CERTIFICATE
I, MIA SOHN, Shorthand Reporter, certify
that I was authorized to and did
stenographically report the deposition of
SHELLEY CHILDERS O'HARE; that a review of the
transcript was requested; and that the
transcript is a true and complete record of
my stenographic notes.
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 any of the parties' attorney or
counsel connected with the action, nor am I
financially interested in the action.
DATED this 4th day of January, 2015.
MIA SOHN, RPR
Shorthand Reporter
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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ERRATA SHEET
F.R.C.P. Rule 1.310 provides in part:
(e) " ... Any changes in form or substance that
the witness wants to make shall be entered upon a
separate correction page by the officer with a
statement of the reasons given by the witness for
making them..."
Page /Line Change /Correction Reason
Under penalties of perjury, I declare that I have
read my deposition transcript, and it is true and
correct subject to any changes in form or substance
entered here.
(Date Signature
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Debra Duran & Associates Page 150
224 Datura Street, Suite 402
West Palm Beach, Florida 33401
(561)313 -8000
Shelley Childers O'Hare
c/o Louis Roeder, III, Esquire
Law Offices of Louis Roeder, III
7414 Sparkling Lake Road
Orlando, Florida 32819
RE O'Hare v. Town of Gulf Stream
DEPO OF: Shelley Childers O'Hare
TAKEN December 19, 2014
Dear Mrs. O'Hare:
This letter is to advise you that the transcript of
your deposition is completed and is available for
reading and signing.
Please make an appointment to read and sign the
transcript. Our office hours are 8:30 a.m. to 5:30
p.m., Monday through Friday. Depending on the
length of the transcript, you should allow yourself
sufficient time for review.
If the reading and signing has not been completed
within 30 days or before the start of the trial of
this matter, we shall conclude that you have waived
the reading and signing of the deposition
transcript.
Your prompt attention to this matter is
appreciated.
Sincerely,
Mia Sohn, RPR, Shorthand Reporter
CC: Robert A. Sweetapple, Esquire
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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1 6:10,14 55:6,8,23
59:8,18 60:8,20,21,
24 61:16 84:11
145:23
1,600 100:1,5,24
1/12 95:23 96:1,4
101 52:17
12/22 95:9
12:00 95:10,23
96:4,25
12:15 93:16
13 65:14 66:20
72:16 111:22
13th 64:1972:23,
25 73:18 74:5
80:17 84:14,15
87:4,6 93:13
111:25
14 79:180:15
82:11,12
14th 79:2180:3,18,
19,22 81:16 82:7
15 19:7
15th 97:14
16 22:15 96:21,23,
24
18 19:7
18th 98:11
1974 18:14
1990 19:5
1990s 8:2 28:8
29:191:21
1997 5:24
1998 6:57:11 13:3,
11,13,17,22 19:5
31:17 36:8 54:12
55:24 59:4,18
62:15 63:2 64:19
68:2 69:8,19 73:18
74:5 79:180:13,15
82:13,20 84:21
85:16,22 90:19
91:16 96:15,16
106:10 111:8
124:5,22 133:6
134:4,8,11,15,19
135:2,4 136:19
144:12,19,20
145:11
1999 5:24 6:5 7:11
95:20 97:18 98:4,
14 99:12
19th 4:2
2
2 6:10,1455:6,9
59:18 60:8,21
61:19,2173:9
79:23 95:20 97:8,
23 98:1,2,5
20 4:7
2012 52:15,21
2013 42:5 103:4
114:9
2014 4:3 91:15
100:4 111:22
112:12
20th 84:21,22,23,
24
213 114:9
21st 84:22
22nd 93:15 97:14
24 115:3,6 116:2
131:13 144:17
24th 142:22
25 35:5 88:20
26 61:21
26th 60:10
27 60:5 61:21
27th 59:22,24 62:3,
5
28 61:21
29th 114:8
2:49 4:3
4,
3 59:18 60:8,21
71:20 72:10 73:4,
9,23 77:6 78:1
79:20,22,24 80:4,6
124:3
30 82:11 142:3
31 11:727:14
33432 4:9
35 35:13 92:10
36 144:16
3:01 15:21
3:02 16:9,11
3:06 16:11,12
3:15 86:10
3:45 98:11,20
4
4 59:18 60:8, 77:21
78:1,5 79:19,25
80:9
4 -21 85:3
4/14 72:17
40 114:10
4:22 93:7,9
4:31 93:9,10
4th 60:9
C;
5 99:21,25 112:14
145:24 146:2
50 88:19
5500 4:9
5:00 123:5 131:10
5:24 146:8
6
6 68:2
60 52:24
6th 67:2568:1,10,
18
7
7 80:13
7 -13 87:2
7th 78:8,19,21
79:20 80:22 81:9,
12,16,19 82:1,7
97:12,16
8
8 62:3 72:17 79:1
85:3
800 101:1 131:14
135:18
8th 94:10,20,25
9
90 52:24
90s 7:3 25:25
26:10,18 27:2,3,8
32:16 82:23
98 55:8 60:2,4,7
99 55:8 60:3
9th 96:25 97:11
A
A -p -t 71:19
A- v -e -r -y 140:23
a.m. 62:3 72:17
79:1 85:3
AAA 44:3
absolutely 88:5,
12, 90:22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
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abuse 134:18,21
135:4
access 102:18
act 11:1715:18
acted 10:2311:16
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acting 100:25
action 21:24
103:16,17 1062,11
135:13
activity 135:8,23
address 141:12,15,
22
addressed 84:8
admission 143:4
admit 138:16
adopt 96:14
adopted 144:14,
16,17
adoption 144:13
145:1
adoptions 144:23
145:12
advancing 106:22
advantage 91:13
adverse 136:7
advised 78:22
81:21
advocacy 92:19
advocate 7:14
91:21,25 92:17,20,
24 93:2
advocated 133:12
affidavit 75:22
76:8,11,17
affiliated 12:10
affirmative 46:21
afternoon 5:6
age 96:24
agency 112:19,20
agents 100:7 101:2
118:8
agree 78:17
agreement 8:9
74:2 138:22
agreements 8:3,5,
6,8,12 139:10
ahead 27:635:21
137:20
aid 65:1
aids 15:25
allegation 32:10
59:3 134:21
allegations 16:20
17:11 129:13
allege 48:4 80:24
100:25
alleged 17:13
30:12 33:5 45:1
61:17 62:164:7
Americo 111:23
ammunition
114:23
amount 138:18,21
announce 4:13
answering 9:9
answers 14:24
anymore 82:8
apartment 11:25
12:19,21,23,24
13:2120:17,18
24:11,12,19 26:18
27:2128:25 31:1,
5,1138:7 68:5,9,23
71:19 72:10 83:16
84:1 126:5
apparently 22:5
appearance 39:2
138:25
appearances 4:13
appeared 35:8,9,
11,12,19 36:12
40:19 70:13 71:1,
15 72:19,20
appearing 35:14
38:23 70:14
139:17,20 140:3
appears 38:24
130:25 143:4
application
122:16 136:23
137:1
applied 90:4
140:7,10
applying 44:15
122:11
appointment
86:12,18 94:23
97:5 98:17 99:6,7
appointments
61:3,4,9 98:15
99:3
approval 53:21
approved 53:15
136:22
approximately
101:1 115:3
April 68:2,4,10,18
72:16,23,25 73:18
74:5 78:8,19,21
79:1,20,2180:3,13,
15,17,18,22 81:12,
16,19 82:1,7,12
84:14,15,21,22
97:12,14,16 98:11
area 115:18
arguably 15:13
argue 106:20
arguing 107:2,4
argument 107:6
111:5
article 102:10
103:11
articles 39:5,6,13,
15,19
ascertain 63:18
aspect 55:25
assert 17:2
assertions 22:8
assessment 16:8
assist 51:6
assume 6:787:19
135:20
assuming 114:22
assure 131:15
assured 130:24
attached 6:15 73:6
77:23 99:22
attending 63:16
attorney 6:3 10:23
11:16,17 15:3,16,
17 16:16 19:2,10
20:2,3 21:25 32:6
52:15 62:19,24
68:23 69:1,2,4,6
74:12 75:8 87:18
89:21,25 90:7
106:18 109:9
113:4 123:12
124:4 125:25
126:1 128:5,7,18,
24,25 129:15
133:17 138:24
140:4,9,16 143:3
145:5
attorney's 15:12
69:11 107:10
138:19
attorneys 4:12
15:9 30:15 35:24
54:9 62:20 106:17,
21 123:13 127:15
August 144:15,19
authorized 110:24
avenues 145:5
Avery 140:18,20,
22 142:6
aware 12:12 14:18
35:7,18 37:11,18
38:9,23 40:18,24,
25 41:1,3,8 42:15,
19,24 43:6 47:20,
22,25 49:19 70:14
71:15,25 76:10
77:4,1193:22
97:19 101:4 102:5
103:1,8,11 104:24
111:21 112:3
114:8 115:2,19
116:10,13,21
118:13 120:1
123:22 127:3,20
133:8 136:4138:2
139:9 141:18,21,25
Awareness 134:4
awful 129:4
B
babies 144:18
145:12
back 13:15 16:13
19:7 21:14,15,19
22:14,23 25:9 28:8
31:17 36:8 46:1
47:9,1168:3 70:6,
7 83:191:2193:11
133:14 144:12
145:15 146:6
badgering 108:18
111:13
banned 142:22
bar 118:16 136:4,
12
based 9:1014:24
27:12 67:175:9
88:15 120:21
basing 36:4
basis 106:6115:11
139:14
Beach 98:19
beat 111:14
began 145:3
behalf 4:1921:23
70:15 83:20 126:9,
10 142:3
belief 14:25
beliefs 109:12,17
believed 136:22
believes 29:4
128:6 129:15,20
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: agents -bring
believing 9:4
big 21:24
bill 84:3
billing 88:3126:15
Billy 141:2,8
billytrasher@
gmail.com 141:13
birth 127:15
145:6,7,14,16
bit 58:21
black 90:5
blocked 20:15
27:22 127:9
blocking 83:12
Bo 4:10
board - certified
35:4
boat 120:2,8
Bob 5:933:12,14
69:3 73:20 92:13
103:12,20,21,22,25
109:24,25 113:4
Bobby 141:4,10
142:4
bobbygangrene@
gmail.com 141:16
Boca 4:8,9
book 97:21,25
born 144:15
bothered 76:21
bought 13:1
box 55:17
brand 144:18
break 15:11,20
92:13 93:6 123:5
breeze 127:10
breezes 20:16
27:22 83:12,18
bring 6:2 38:12
41:3 43:25 46:1
52:16 135:12
brings 131:21
Broeker 4:18 5:23
79:6
brother 18:3
19:20,23,24
brought 38:10,13,
14 40:13,20 88:16
111:2,3
building 12:1,20,
22,24,25 13:21
20:17,18 24:11,12,
26:19 27:2128:25
31:2,5,12 38:7
68:23 84:2 126:5
Burp 111:25112:4
business 21:18
85:6 112:16
busy 34:15,17
96:16 144:24
C
calendar 7:8 58:15
59:19 60:23 62:1
67:3,9 72:3,18
73:19 98:15 99:4,
8,16 132:6
calendars 6:5
34:16 38:10,19
57:7,12,16 66:25
call 17:19 19:9
33:12,14 47:9,11
85:7,12 86:5 98:25
126:3
called 5:1 17:19
19:12 117:1
118:18 127:25
141:13,16
calling 31:24
33:13
calls 85:5116:23
calm 69:23
canal 120:3
cancelled 7:248:2
38:15
capacity 19:1
cape 75:14
car 90:11
card 39:11
career 90:9
case 5:13 9:18
35:8,19 39:2
40:18,19 41:6,8,15
46:18,21,22 47:6
76:22 77:18 88:11
90:22 103:2, 106:9
111:1 123:25
124:22 133:1,4,5
134:22 136:8,17
138:25
cases 5:1041:2
52:16,17 116:22
118:1,3 123:23
138:14 139:7,20
140:4,6,9
caused 100:2
CFO 85:6,9,12
86:5 98:11
chambers 35:24
36:7,13,16
chance 5:1615:19
16:15 106:20
Chandler 41:24
42:1,4,6,9,10,11,
12,16 43:11,21,22,
24 44:2 48:11,14,
15,16 49:6,9,16,19
50:1,4,8,13 51:1,5,
11,20,22 52:3,11,
20,22,23 53:1,3,5,
20,24 54:9 101:15,
20,25 102:1,3
105:19 119:3,9,11,
12,14
Chandler's 50:21
check 8:16,19
87:22,24
checks 7:24 8:2
38:15
Childers 4:5,25
childhood 18:3
31:18
children 96:15
144:14
Chris 7:17 10:10,
14,16 11:7,18,21,
23 14:4 21:17,22
23:20,25 24:18
31:2,12,14,23
32:19,22 33:1,6,16,
19 34:1,7,2136:5,
6,12 68:22 83:13,
14,15,22,23 84:1
85:7,10,1187:5
88:2 89:8,9,15
91:20 96:19 98:12,
20 99:10 101:22
114:24 117:9
127:18 130:7
133:17 135:6
Chris' 33:2157:6
80:7 97:20,22
110:10
Christopher 4:5,
15 5:22 78:20,23
81:11,22
circle 61:7
circumstances
142:12
circumvent
142:16
Citizens 134:3,10
city 20:2165:18
civil 135:12
claim 34:20 138:13
claimed 127:9
claiming 82:13
claims 46:6
clarify 71:12
clarifying 71:3
class 19:21
clean 56:4
clear 9:12 90:4
110:22
client 11:2,11
89:22 90:7,8
clients 88:1790:11
128:24 132:12
Index: brings-conversations
close 19:1447:11
105:21
closing 47:3 62:25
81:6
closings 35:15
89:2
clue 67:18
Coastal 101:23
102:10 103:12
code 12:313:6,20
14:120:20 27:25
28:2,3 37:13 58:9
70:21 73:11 77:18
78:24 79:1181:6,
24 82:10 89:2
106:9
collect 44:4
Comm 67:22
commission 35:23
36:7,13,15 146:23
communicate
118:22,25
communicated
83:13,22
communicates
42:25
communication
16:6 88:15
communications
14:16,23 26:22
127:19
companies 45:2
company 134:3
compel 46:2
complain 26:7,13,
24 129:21,23
complained 83:11
136:21
complaining
83:17
comply 58:2
composite 99:25
concern 7:10
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
concerned 20:11
109:16 116:5
139:6
concert 101:1
conclude 6:21
143:25 144:2
concluded 53:4
146:17
conclusion 28:20,
22 40:9 52:8 98:9
conclusions 22:9
confer 15:24 16:16
conference 51:19
58:8 68:5,8,9,12,
17,2170:13,15,18
71:2,19 72:10
conferences 71:16
confide 11:14
confided 7:13
10:23 11:13 14:5
15:2 128:17
confidential 16:6
128:23 130:15
confusing 104:14
conjunction 18:7
conserve 136:25
consistent 61:23
consult 49:20
consultant 43:24
consulted 50:8
contained 112:12
context 37:25
contingency
139:14
contract 10:22,25
11:1,5,9
contracted 15:1
contrary 75:23
conversation
88:21
conversations
14:4,13 16:19,22
17:23,24 23:21
31:13 32:18,21,23,
25 33:3 34:1,2,8,12
45:16 53:1,2,19
91:20 130:22
133:16
converted 13:2
convinced 69:8
Cooper 4:10
copies 6:14 8:5
copy 6:8 73:5
77:22 97:18 99:21
100:19
copying 142:16
corner 96:2
correct 6:5 8:2
10:3 13:8 14:11
18:9 19:121:5
33:10 55:7,10,13
66:23,24 74:22
119:23 120:22
135:14 144:21
corrupt 134:15
cost 142:12,16
council 65:18,21
counsel 16:17 17:6
29:13 77:12 79:9
107:15 108:12
counsels 132:20
counterclaim
134:23
counterclaims
46:22 111:2
couple 95:4
court 106:22111:4
123:23 146:13
courts 28:19
cover 60:17,19
created 141:13,16,
22
credit 39:11
crime 103:17
135:7,8,14,15,23
criminal 135:10
CROSS 144:8
crummy 89:20
current 124:19,22
132:25 136:8,17
D
Dale 19:22
date 61:20 64:12,
15 65:14 67:24
78:7 81:18 95:24,
25 114:15
dated 18:3 78:21
79:20,2180:13,14
81:19
dates 82:20
daughter 144:15,
17
day 4:2 60:7 74:21
87:5 96:8,1197:6
days 82:11
daytimer 55:19,20
daytimers 55:18,
21
deal 33:23 110:25
111:2 122:16
dealing 110:23
127:15,16
dealings 21:18
33:21
dealt 7:12,18
10:10,16 22:18,20
23:10 24:22,23
68:22 89:23
debate 82:9
deceased 19:25
December 4:3
94:10,12,20,25
96:15 103:4
144:16,19
decide 17:129:17
107:9 135:25
decided 25:9
Defendant's 6:13
73:4 77:2199:20
defense 17:6111:1
defenses 46:22
definition 82:2
delivering 45:12
Depends 116:1
depo 73:9,10146:7
DEPONENT
146:20
deposition 4:4,7
5:15 6:10 35:11
45:19 46:1,4,12,15,
23 47:4,10 58:20
71:8 76:20,24 78:2
80:8 88:4 110:23
139:4 146:9,16
depositions 35:15
describe 52:11
destroy 103:15
detail 24:22
100:12
detailed 29:21
determine 28:21
Diane 18:4,5,7,25
19:3 20:1,24 31:18
88:25
difference 81:17
125:2
direct 5:4 101:2
disclose 16:18
discuss 21:942:16
44:3 47:12 50:21
105:14,18
discussed 15:3
22:16 29:22 30:11
39:9 44:10,24
48:8,9 53:22
101:14,17 102:20
130:6,7
discussing 48:12,
13
discussion 53:13
dispute 74:24
disputes 124:8
disqualification
45:20 46:12,16,19
disqualify 17:6,10
40:7 45:23 46:5
divulge 14:23
document 37:20
38:3,6,9,24 68:20
73:3 77:20 98:10
105:1,4,8,12 132:8
documents 5:17,
20 6:3,12,17,19,23,
24 7:1,7,9,17,19,
20,21, 39:22,25
46:2 54:15 55:11
99:19 126:9,16
142:11
door 20:14
doubt 51:4
dozen 81:3
dozens 45:7,11
drawings 120:2
driver's 145:17
dropping 82:6
duly 5:2
duplicate 146:4
E
E -d 81:25
e-mail 141:22
early 92:19145:8
easier 56:5
Ed 86:8,9,10,12,14
Edwin 37:9,12,19,
24 38:2 73:25 74:9
76:25 77:2,4,8,11,
17 79:8,17
election 119:6
electricity 136:25
employed 126:12
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: converted- Expires
employees 120:17
employment
138:8
end 36:16 137:24
146:9
ends 56:25
enforcement 12:4
13:7,20 14:135:16
37:13 58:9 70:22
73:1177:18 78:24
79:12 81:24 82:10
entitlement
138:17
entity 12:9,24
entries 57:8,13
60:25 78:13
entry 55:2463:5
64:6 65:14 66:8
equally 122:11
equals 80:22
Esquire 5:23
estate 62:25
ethical 92:12
event 10:3
evidence 125:23
exact 115:5
EXAMINATION
5:4 144:8
examined 5:2
excerpts 6:4 7:8
execution 75:24
exhibit 5:17 6:13,
22 55:23 59:8,18
60:24 61:16 73:4,
9,23 77:6,2178:1
79:19,20,22,23,24,
25 80:4,6 84:11
95:20 97:23 98:1,
2,5 99:20,25 100:9,
18,20 1 12:14
exhibits 6:10
95:21 145:23
Expires 146:23
explain 139:23
explained 56:9
expressed 122:20
extent 47:5
F
face 9:16,17
fact 13:6,25 28:19
50:22 58:17
142:20
facts 28:21 103:8
109:14,15 125:23
factual 22:8
factually 81:2
fair 6:21 16:7
fairly 44:16 135:9
fake 44:22 46:25
142:17 143:15
fall 52:14,21
family 31:20 88:18
103:14,15
father's 119:7,18
Faulk 18:4,5,7,25
19:3 88:25
February 64:21
65:14 78:13 96:25
142:22
federal 123:23
fee 7:25 8:3,5,7,9,
11 139:10
feel 133:10
feelings 22:6,22
feels 112:17 122:10
fees 138:9,14,19,22
fence 23:23 69:5
81:4
fictitious 46:25
100:7 143:10,14
fight 21:1689:23
figure 47:13
114:21
file 25:9 105:20
106:6 126:11
134:23 137:5
filed 17:3 20:21
42:20 45:5 47:2,
21,23 48:2 75:22
76:8,13,17 100:2,5,
25 101:2,11 102:6,
11 104:6 108:23,25
109:1 114:9,14,18
115:3,6,9,12,20
116:2,10 118:7
123:22 126:7
129:6,7,11 138:3,5
142:3
files 38:18,2044:7,
11 58:1 87:20
filing 21:22 28:15
42:16 43:8 44:18,
21,25 46:6,21 51:6
85:8,13 86:6 101:5
104:4 115:23
final 79:20 80:18
finalize 144:23
finalized 145:18
find 21:12 87:24
90:1 100:15
130:11
fine 25:8 106:23
115:1
finish 31:8 123:7,8
firm 7:3, 8:10,17,
20 11:1 13:19 14:1
39:23 40:10 55:25
57:9 58:24 59:4,20
61:17 62:2,8 64:1,
8 66:10 77:9,12
78:15,20,22 79:9
80:21,24 81:5,10,
13,2184:4,7 87:10,
13 89:4,6 94:18
98:4,8 99:12,14
105:19 116:14,23
117:1, 118:2,
134:7, 138:8,9,14,
23 139:11,14
firm's 16:20
fish 106:19
fit 41:3
Florida 4:8,9
101:21 104:8
118:9,16 136:4
140:8 145:16
focus 145:11
focused 96:18
follow 59:9
follow -up 85:5,11
92:15 144:10
form 27:5 33:7
34:4,10 35:20
37:15 39:24 40:15,
22 49:23 50:17
51:8 52:5,18 70:16
75:25 76:6 89:18
90:12 103:6
104:11 105:23
106:5 134:20
formed 52:2
forward 45:24
47:18 94:11,12
107:3,6
Foster 4:19
found 55:14 88:1,2
145:5
Foundation 134:4
four - month -old
96:12
frame 83:6
Friday 64:18
friend 18:3 19:21
31:18
friends 19:14,23
88:19
front 7:7 55:4
59:8,13
full 92:6
function 36:21
future 61:6
G
Gangrene 141:4,
10 142:4
gave 54:9 56:5
76:23
general 44:13 58:5
generally 117:23
geographically
124:25
give 82:16,21
109:12 112:18,21
121:10,15 142:20
146:5
giving 14:5 17:17
33:167:5 69:25
70:2 75:18 113:1
142:22
gonnawhite@
gmail.com 141:22
good 5:6 7:14
19:22 25:4,6,20
110:8 132:4
Government
47:3,4 112:18,19,
20 134:10 135:22
governments
118:8
graduate 18:13
Graphicworks
4:11
great 25:5,21
96:24
group 100:25
guess 17:133:12
54:17 92:18 96:22
guessing 9:11
98:13
Gulf 4:6,205:10
21:23 23:24 25:4,
6,15 29:5 40:13,14,
2141:2,19 43:9
44:8,12 47:21,
50:24 53:22 89:11,
15 90:18,24 91:7,
15 100:8 101:12
102:8 103:13,23
104:5 105:2,11,22
106:3,15,17 108:1
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: explain -Hanna
109:2,9 114:11
115:4 120:3,17
123:10 124:20,25
125:3,10,12,14
133:16,18
guy 130:18
guys 58:8,10
W
hac 139:17,20
140:7
half 131:23,24
hall 64:1165:15,17
66:13,17,2172:18,
22,24 73:18 74:1,4,
21
handed 6:3,6,7,9
handle 22:17
88:10 127:18
handled 22:18
27:2,18,20 31:12
80:25 82:10 83:23
handles 90:7
handling 34:20
40:19 132:1
136:18
handwriting 57:4,
6,23 72:2 85:20,23
86:16,17 97:24
Hanna 4:15 23:12,
15 27:4 33:7 34:4,
10 35:20 40:15,22
45:13 46:7,13
47:16 49:3,23
50:9,17 51:8 52:5,
18 53:16 54:17,20,
24 57:25 58:11
59:10 60:1167:12
68:13 69:10,14,23
70:12,16,20 71.3,7
75:25 76:6 78:4
80:7 84:16,18,23
89:18 90:12 91:17
92:13 101:7 103:6,
10 104:11 105:23
107:20 109:18
110:17,20 111:17,
19 113:3 116:15,19
122:2 123:19
125:5 126:18
130:12 131:2,7,16,
25 132:18 134:20
137:7,22 138:10,16
142:19 144:9
145:20 146:11
happened 31:4
49:18 90:23 91:16
128:22 136:19
happening 20:8
happy 25:3123:6
harass 137:5,10
harassing 137:12
hard 65:2
He'll 25:20
head 74:19 111:15
113:17 118:14
119:19 143:24
health 128:8
129:17
hear 37:8 51:25
65:5,10 70:8 77:2
heard 18:637:10
48:13,15,16 49:11
51:23 75:18 76:25
81:2 101:23 117:9
132:16
hearing 15:25
35:12 36:14,20
45:25 65:1,2 70:22
72:17,18,20 109:7
hearings 35:14,16
heart 127:17
Heath 58:6 93:16,
17,23,24 94:1,4,5,
7,20,23,25 95:10,
14,23,24 96:4 97:1,
6,9,11,12,14,15,18
98:8,12 99:7
129:21,24 130:2,5,
7,20
held 4:7
helping 53:10
Henry 112:8
hereinafter 124:9
hereto 6:15 73:6
77:23 99:22
high 18:8,11,15,18,
20
highest 19:19
hire 37:1243:21,
22 106:17,18
109:9,10 123:11,16
hired 7:1321:4,8
22:17 25:3,16
31:18 81:9 128:17
hiring 31:19
hold 19:1922:11
home 96:13
hoping 55:8
hour 131:23
hours 114:9
131:23,24 144:16,
17
house 36:22,25
37:3 96:18,20
98:16 119:7,18,20,
21,22,24 120:9
144:18
household 79:17,
18
hundreds 42:16,
20 43:8 44:18,25
102:6,7 104:5
105:20 110:14
118:7
hurt 92:18
husband 5:11,21
6:207:2,11,12
11:23 12:9,18
14:10,13,16,22
15:1,8 16:19 17:3,
14,21,25 19:11
21:122:13,16,18
23:9,11,19 24:13,
20 25:13 26:3,17,
22 27:13,15 28:6,
23 29:3 32:11,12
35:8 36:24 37:2,
12,20 38:2 39:4
40:11,20 41:3,18
42:5,7,13,15,19,25
43:7,18,22 44:6,11
47:2149:20,25
50:7,14,22 51:2,6,
12 53:11,13 54:8
55:14,16 57:11,18
59:4 62:14 63:20
64:2,9 65:18 66:15
67:5,6 70:15
71:16,18,25 72:9
73:25 74:6 75:10
77:16 78:14 79:10
82:14,18,22 83:20
86:19 88:6,9,13
93:22,25 94:22,24
95:1,2,6 96:2 98:6
100:2,5,6 101:2,4,
11,15,18,19 102:2,
6,12 103:3,14,16,
24 104:18,25
105:10 106:3,7
107:24,25 111:1,3,
21 112:10 114:5,9,
18 116:2 117:5,14,
21,24 118:3,18,22
120:2,16 121:24
124:6,13,16 125:9
126:25 127:4,20
128:10 129:6,10,19
130:3,10,24
131:13,21 135:17
136:21 138:3
139:10,17 140:2,15
141:1,6 142:15
143:9 144:3
husband's 15:2,5
16:16 17:5,9 38:14
40:6 43:13 51:18
52:9 53:2158:25
61:4 63:8 67:1
69:20 71:24 73:10
75:23 78:197:17
98:14 99:3 113:14
123:2,22 130:21,22
131:1 137:19
husband /wife
14:15,19 15:6,13
16:21
hypocrite 120:11,
12
Hypocrites 112:6
I
Idea 41:2169:7,9
82:16 108:7,9
112:10,16 113:13,
15 114:4 116:7
122:1,4 142:7
ideas 110:11
identification
6:14 73:5 77:22 -
99:21
Ignoring 65:3
illegal 135:23
Imagine 92:7
important 115:20,
23,24
Inappropriate
143:7
included 126:23
independent
17:12
indication 130:1
individual 124:9,
12
individually 12:9
100:6
influenced 134:15
information
29:10,2132:9 36:5
104:23 128:8
129:17 130:15
initially 123:3
insignificant
88:10
instance 9:23
33:16
Instituted 5:11
Instruct 45:13
138:11
instructing 30:2,6
instructions 76:23
intend 111:4
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: happened- issues
intent 16:18
intention 14:14
72:13
Interests 136:7
interpretation
29:16 71:22
Interrupting 31:9
intimate 21:16,17
92:1 110:10
intimidating
131:17
introduced 51:20
invoice 87.2,3,7
invoicing 88:3
invoke 45:1546:7
Invoking 16:21
29:18
Involve 54:12
123:25
involved 19:8
54:12 62:14 63:1
70:20 83:2191:12
104:21 124:7
126:17 133:22,25
134:4,8,11
involvement
83:20 88:9
Involves 41:6,8,15
Involving 24:14
31:4 38:7 39:6
74:24 89:13
125:10 127:4
134:25
issue 12:4,21 13:7
14:3 20:4,10,12,24
22:16 26:8,9
27:24,25 82:21
83:19 125:17
127:12
issues 11:18,21
22:12,19 23:21,22
24:1,8,15,16,17,18,
2125:1,24,25 26:5,
16,25 28:5,22 31:4,
12 33:2134:20
36:9,10 69:19
75:16 83:3,5,9,10,
21,23 90:19 91:11
96:19 104:4
127:13,18 133:11
item 67:3 93:14
J
January 59:18,22,
23 60:5,9,10, 61:21
62:15 63:2 96:13
Joanne 4:18
job 7:1425:4,6,20
75:21 110:8
Joel 41:24 49:4,6
101:15,20 102:1,3
joined 21:15
jointly 31:2
Jonas 37:9,12,24
38:2 73:25 74:9
77:1,2,4,11,17
79:8,17 80:20
81:5, 86:8,10,12,14
87:11,16 89:3
126:16
Jonas' 77:8
Jonathan 117:2,41
7,10,12,15,20,23
118:15,19,20
119:13,16,24
133:25 139:16,19
140:3,6,11,14
Jones 37:1979:11
86:9,10,14
joy 96:18
joyous 145:19
judge 29:17107:9
judge's 28:21
July 87:4,6 93:13
jumped 21:1981:4
jumping 23:23
28:15
jury's 135:24
IN
keeping 67:19
Kelly 140:18,20
142:6
Kenny 19:20,22
kids 96:21
kill 44:4
kind 20:4 108:14
King 58:7 88:16,
19,20 93:16,17,23,
24 94:1,4,6,8,20,
23,25 95:10,15
96:4,5,7, 97:10,16
98:13 129:21,24
130:2,5,7,20 144:4
knew 25:18 26:4
61:6
knowing 74:8
knowledge 8:1,7,
9:11 12:7 17:12
21:16,17 31:23
32:9,13,15 33:25
61:13 66:17 69:16,
18,19 70:24 82:23
92:193:4 109:15
110:10,13 118:19
L
label 146:1
labeled 145:25
Larry 98:18,24
late 7:3 25:25 26:9,
17 29:1 82:23
law 7:3 8:10,17,19,
22 10:8,10 44:15,
17 64:8 69:17 77:9
84:3,7 90:5,6,15
91:10 92:9 105:19
107:9,10,13 112:24
116:14,22,23
117:1, 118:2,7
122:11,16 134:7,8
138:9,14,23
139:11,14
law's 122:12
laws 28:18
lawsuit 40:13
106:6 114:23
116:10 126:23
127:1,4,11,21
129:7,11 134:23
138:5
lawsuit's 115:23
lawsuits 35:6
47:23 48:2 62:17
115:3,6,12,19
116:2 126:8
131:13,21
lawyer 16:635:2,
5,16 37:8 38:13,14
lay 26:14
leading 13:24
leave 15:23 16:3
29:16 34:2146:11
lectured 40:10
legal 4:11 11:18,21
12:7,21 20:4,10,12,
24 22:9,12,15,19
23:8,10,18,21,22
24:1,8,15,16,17,18,
2125:1,23,24
27:15 28:20,21
34:19 36:8,10
37:19 38:18,20
68:23 69:19,25
70:3 75:16 82:13,
16 83:3,5 87:20
88:11,23 89:14
90:19 92:1196:19
106:11,21 109:16
112:22 113:1
117:18,20 120:19
126:8 127:12,13,18
133:11
legally 69:8 123:17
legitimate 135:18
letter 78:3,2179:2,
19,24 80:1,12
81:18 90:5
letterhead 79:5
letting 67:18
limited 47:6
listed 62:12
litigating 116:8
litigation 29:6
58:4 63:1 134:19
live 119:24
living 48:18 49:2
LLC 13:2,3,7,13
31:3
LLCS 13:10,17
locate 6:17
located 6:19
long 33:17,22
131:10,15
longer 58:21
looked 7:6,19,22
34:16 40:4,5 58:14
99:15 101:10
102:23 114:17
lot 20:14 22:819
102:11 122:24
144:22
lots 106:16 123:12
Lou 4:2143:17,20
49:13 51:19,20
76:23
Louis 18:3
lucky 55:9 96:14
W
M- o- r -g -i -n
141:24
made 15:5 22:8
41:18 67:10 70:12
71:10 103:3
107:25 108:3
113:14,16 114:5,21
118:13 121:24
126:17 129:13
138:24
major 115:24
make 44:349:2,19,
21 50:1 51:13 52:8
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: item -means
56:2 65:8 67:4,8
113:19,21 114:3
125:2 143:10
145:22
making 45:16
48:18 49:1,9 51:23
70:25 71:8 110:14
135:6 137:23
man 51:17 74:8,9,
11
March 66:20
78:13 97:8,11
mark 4:15 6:9
23:14 55:4 60:3
99:25
marked 6:13 55:6,
17 73:4 77:21
78:14 99:20 121:9,
12
marking 73:8
marks 146:9
married 11:7,19
Martin 43:3
116:11 133:22
Martin's 119:20,
24
master 73:11
78:25
material 106:1
materially 136:7
matter 4:5 12:13
14:1 15:4 24:12
45:18 79:12 81:7
82:10,16 84:12
90:7 109:17
126:14 133:23
134:1 136:6,16
matters 27:18,20
30:24 62:15 68:24
82:5,13 88:11
89:14 99:3 124:18
126:23 127:17
mayor's 120:9
means 14:20 85:9
133:3
mediation 35:13
mediations 35:15
meet 9:1 11:14
42:4,6,8,10 43:12
52:22 53:3 74:11
meeting 10:3
34:14 49:16 59:21
60:162:3,6 63:5,9,
11,12,14,15,16,21
64:10,18 65:15,17,
22,24 66:1,3,6
67:22,23 74:8,9,14
76:4 87:5 88:12
98:24 130:23
meetings 17:13
58:8 97:19
member 13:10,
118:16
members 88:18
mention 98:7,8
134:14,18 135:4
mentioned 17:21
18:120:7,9 24:10
28:24 39:6 58:5
102:10,11 136:24
144:12
met 8:249:2,7,15,
17,19,21,24 18:22
41:23 42:1,2,3,10,
15,22 43:7,48:11
51:22 52:3,9,22
53:3 74:14 76:9
88:6,14 117:16
119:2,6,16
mind 16:3 67:19
91:22 92:2 121:19
127:17 131:1
mine 19:2160:9
96:2 121:10,15
Mine's 96:24
minute 36:10
97:13
minutes 66:5
Misebaracterizati
on 33:8 76:1
142:19
Mischaracterize
122:3
mischaracterized
70:17
Mischaracterizes
23:13
missing 60:16,19
Mm -hmm 35:17
65:16 95:1197,2
118:11
modus 52:12
moment 64:23
Monday 45:12
67:25 74:5 86:11
87:3,6 88:2
money 44:450:1
104:9
moneys 87:11,14,
17
month 99:6
months 25:14
26:2,6,21,23 27:1,8
29:4 30:12 33:11,
15,19 34:3,8 103:5
145:2
Margin 141:24
mothers 127:15
145:6,8,15,17
motion 17:3,6,9
40:7 45:20,23 46:4
123:3,7 129:5,6,11
mouth 91:3137:15
move 46:2,847:16
115:15
moves 74:19 77:15
113:17 118:14
119:19 143:24
moving 26:20
multiple 34:2,7
Il
named 11:1037:8
39:13,16 74:11
names 44:2245:1
46:25 100:7
142:17 143:10,14,
15
nasty 137:16
nature 89:3
needed 104:25
105:1
neighbor 20:13
27:2128:13 63:2
83:11,17 106:13
127:8
neighboring
126:24 127:1,4,22
nervous 145:14
newborn 96:13,20
newborns 96:17
98:16,22 127:14
newspaper 25:2
39:5,6,13,15,19
newspapers 39:12
Nicoletti 74:1,12
75:22 76:8
nonsense 111:5
noon 94:21,25
Nos 6:14
not - for - profit
45:2
not - for - profits
46:25
Notary 146:22
notation 95:22
notations 67:5,9,
10 97:17,20,22
98:6
note 56:3 58:24
67:12 72:5,8 85:11
noted 93:17,19
94:14
notes 56:20,21
58:25 67:17,21
notice 5:20,24
14:12 39:2 46:17
47:6
noticed 46:16
noting 23:15 94:22
Nova 18:8,13,15,
18,20
November 93:15
111:22,25
number 17:428:9
88:2 102:9 115:5
145:4
numerous 32:16
91:19 116:22
133:16
nursery 127:16
L]
O'boyle 42:22,25
43:3,7 105:19
116:11,14,23
117:2,3,4,8,10,12,
15,24 118:2,6,15,
19,20,23 119:13,16
133:22,25 138:8,9,
14,23 139:11,14,
16,19 140:397,11,
14
O'boyle's 46:24
119:22
O'boyles 44:25
O'connor 4:19
56:18
O'bare 4:5,6,16,
22,25 5:22 17:14
23:18 45:14 54:22,
23 55:2 57:25
69:2178:20,23
81:11,22 88:2
116:21 121:9921
143:2
O'hare's 46:24
143:3
O.R. 72:17
oath 9:9,15,20
object 23:12 27:4
29:8 33:7 34:4,10
35:20 40:15,22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: mediation - opened
46:14 49:23 50:17
51:8 52:5,18 53:16
69:10 70:16 75:25
76:6 89:18 90:12
91:17 101:7 103:6
104:11 105:23
125:5 134:20
137:7,8,13 138:11
objection 23:16
47:7 50:9,18 70:2
71:2178:16 91:18
92:21,25 104:10
105:24 106:25
111:6 116:15,16,17
120:18 122:2
142:18 143:6
occasion 9:25
occasional 14:6
31:16
occurred 130:25
ocean 9:2 11:19
12:1 13:22 20:8,
13,15 22:19 23:23
24:14 25:19 27:22,
23 28:10,12 29:1
31:5 37:2138:1,6
40:12 58:4,7 62:10
68:24 70:2173:12
81:7 83:4,12,18
89:13 90:24 91:6,
16 106:12 110:16
124:8,9,10,12,24
125:3,20,21 126:4
127:2,6,7,10 128:2
133:13,23 134:1
office 8:22 10:8,10
43:13 51:18 52:9
53:2188:23
officer 115:14,16
officials 124:10,12
older 19:24
one's 118:13
one -week 33:23
81:14
onetime 33:16
open 47:2
opened 126:15
operandi 52:12
operated 52:12
opinion 52:270:1,
3 81:1 82:19
90:15,2191:1,4
95:18,19 107:16,
17,19 109:16 116:1
opinions 109:13
opportunity 67:6
opposite 106:16
order 44:4 53:14
73:10,13 79:20
80:14,18 104:8
105:21 142:16
organization
104:6 134:15
organized 103:17
135:7,8,14,15,23
out -of -state
140:4,15
overheard 32:24
overlook 67:17
owned 11:2013:2,
3,7,13 20:14 90:8
owner 31:1 126:24
127:2,5,22
owning 12:19
N
P.L. 5:23
p.m 72:10
p.m. 4:3 16:11
71:20 93:9
pages 57:19 98:5
99:16,17 120:15
paid 7:13,2449:25
87:11,16,19,21
128:18
paired 145:6,7
Palm 98:18
panel 136:24
paragraph 124:3
Pardon 19:16
23:14 44:9 73:20
86:2,24 87:12 88:7
96:9 97:4 112:15
120:6
park 125:1
parked 120:8
part 31:10 60:15
70:23 72:3 104:6
110:22 129:6
part -owner 31:11
partner 12:19
party 10:2 32:23
62:17 117:16
119:6
past 9:15 30:25
32:1181:10,25
133:17
Patrick 112:8
Paul 74:1,11
pay 138:22142:12
paying 138:9
142:16
pending 133:5
134:22
people 35:19 44:16
70:20 88:19
100:25 109:10
period 10:1913:2
81:14,16
permission 64:24
permitted 47:5
person 20:13
34:17 135:21
136:5,13
person's 136:7
personal 9:10
32:15
personally 12:8
personnel 124:10,
15
pertinent 139:4
phone 32:25
117:10
photocopying
142:13
pick 103:4
picked 37:2
plaintiff 4:14
116:11 124:5,6,7
127:2 128:4,6
129:15
planted 115:15
pleading 132:10
plenty 109:10
point 14:25 45:19
108:20,21
poke 113:5,6
police 115:14,16
policeman 116:5
ponliricate 47:8
pontificating
111:10 126:21
position 15:14,18
30:23 46:13
104:17 110:23
132:17
positive 115:13
possess 39:25
possibly 62:9
82:22 92:3
Post -it 72:5,8
practicing 92:10
predicate 26:14
pregnancies
145:9
prepare 37:19
prepared 71:12
preparing 106:1
presence 15:12
50:22
present 10:14 16:5
36:2,18 42:12
53:20 75:24
press 58:8 68:5,7,
9,12,17,2170:13,
15,18 71:2,16,18
72:9
pressure 53:14
105:22
pretense 47:2
pretty 11:8 90:4
115:23, 137:24
prevents 111:8
previous 120:21
Prigs 112:6
primary 145:11
prior 22:23 45:20
91:11 102:5
107:22 124:18
133:2,9,22 134:1
privilege 14:15,22
15:7,13,15,19
16:21 17:2 29:12,
14,15,30:19 45:15
46:8
privileged 29:9,23
32:6
pro 139:17,20
140:7
probing 108:14
proceeding 78:25
proceedings 4:1
process 134:19,21
135:4 144:13
145:1
produce 76:12,15
112:20
produced 54:16,
18
production 58:2
prohibit 136:12
prohibits 136:5
proper 89:16
121:4
property 11:20,
126:24 127:2,5,22
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: operandi - putting
proposition
106:21
protected 128:8
129:17
protection 129:2
provide 142:5
provided 98:7
pseudonyms
101:3,5
public 41:9,15,17
42:16,20 43:8,25
44:3,7,11,19,21,25
45:4,7,11,16 46:18
48:12,17 49:1,10,
2150:2 51:7,13,23
52:15 53:14 54:13
100:1, 101:5,10
102:7,24 103:18
104:5,7,18,21,22,
23,24 105:16,21
106:14 107:23,24
108:22 110:14
111:22 1 12:11,25
113:13,19 114:4,
10,17 118:7
120:13,16,19
121:23 122:9,13,
15,20 125:17
126:3,4,8 131:14
135:8,16,18 137:5
141:7 142:2,21,23
143:10 146:22
pull 87:22
pulled 99:18
purpose 47:3
49:15
purposes 46:4,19
51:13
pursuing 110:9
push 108:19
pushing 108:19
put 15:14,1820:15
47:7 60:15 63:7
70:24
putting 91:3
137:15
G
question 7:410:15
12:11 13:14,16,23,
16:24 23:13 26:12
29:20 30:18,20
37:16 39:18 46:9
50:19 53:17 65:4
67:2 68:25 70:5,9
71:7 80:10 82:24,
25 101:8 104:12,
14,15 107:7,11,14
109:19,21 110:17,
20 111:13,17,19
113:22,24 121:3,4,
7,22 122:7 123:19,
20 129:8,9,12
130:13 131:3,16,25
132:18,21 136:9,10
140:12 141:5
142:24 143:4,7
question's 13:15
questioning 47:17
questions 9:9
17:1,9 29:25 32:4,
7 46:3 47:14 52:25
59:17 69:14 71:9
106:4 110:25
120:22 122:24,25
126:20 128:16,20
136:2 144:7
quick 137:25
quickly 123:8
quiet 70:3
quoting 29:17
R
racketeering
134:14
Raton 4:8,9
read 5:16 13:15
17:5,7 48:6 66:12
70:6,7 82:25 90:5
100:10,146:11,12
reading 129:5
136:14 146:18
reads 70:10 83:2
real 62:24
realize 90:14
reason 53:5
113:20 135:18
recall 8:21,23 9:4,
21,22 10:9,12
18:20,24 20:9,23
24:17 30:4 34:24
49:7 50:6 53:19
73:2,14 74:3,4,7,8,
14,15,23,24 75:4
76:5,9 77:3 82:15,
20 83:5,12 84:5,9
85:24 86:1,3 95:16
99:1,10 101:22
105:13,17 121:1
127:23 135:5
receive 84:3,6
received 5:12
87:10,13
recent 142:5
recently 24:25
78:8,20,23 80:12
81:22 82:3
recess 16:1193:9
recognize 67:4
recollection 10:7
41:14 73:17,25
75:13 88:5,12,22
98:3 108:16
120:23 121:25
recommend 21:3
recommended
94:3,5,8 128:5,19
record 4:13 16:10,
13 43:146:11,15
47:8 48:17 51:24
56:2 64:17,23
71:1,6,1193:8,11
112:19,20,25
114:14 120:20
122:9,20
records 7:1,24
41:9,15,18 42:17,
20 43:8,25 44:3,7,
11,19,22 45:1,5,7,
11,17 46:18 48:12
49:1,10,2150:2
51:7,13 52:16
53:14 54:13 57:25
58:18 87:23,25
100:1,101:5,11,24
102:7,18,21,24
103:2,18 104:5,7,
18,21,22,25
105:16,21 107:23,
24 108:22 110:14
111:22 112:11,25
113:13,20 114:4,
10,18 118:8
120:14,16 121:23
122:13,15 125:17,
21 126:3,4,7,8
131:14 135:9,16,
19,22 137:5 141:7
142:2,21,23 143:10
refer 5:217:1
30:14 63:8,12
85:15,17 106:24
reference 63:25
78:24 79:2 81:24
99:18 135:3
references 99:11,
13
referred 6:12 15:4
17:16 19:13 21:7
31:17 73:3 77:20
89:1,2 97:3 99:19
128:14 130:5,18
referring 10:18
11:5 49:3 56:22
58:7 89:9
refers 55:25 58:24
59:3,6,19 63:5
94:24
refresh 41:14
108:15 121:25
refreshes 73:17,24
98:3
regard 13:20
14:15 15:8 19:19
22:12,23 25:1,23,
30:24 37:13 40:11
46:5,24 47:5 77:17
89:11 103:1 104:4
105:16 106:9,11
110:13 125:14,16
138:3
reimbursements
142:6
relate 66:9 87:8
99:12
related 62:8 63:20
72:11 133:2,9
136:6,15,18
relates 61:17 62:1
86:21 91:11 94:18
98:3 133:5
relation 9:18
relationship
33:17 64:7 77:9
89:21 128:23
relevant 58:4
remember 8:12,
13 10:1,4,5,6,9
11:3,12,15 12:5,6
13:5,9,18 14:5
17:16,17 20:5,12,
22 33:136:9 37:1,
6,22,23,24 38:4,5
43:15 49:13 53:2,9
62:13 65:20,23
69:2 93:24 94:5
97:7 102:9 127:14
130:23
remind 61:12
remove 115:17
rephrase 34:6
40:17 100:3,23
121:6 140:13
reporter 70:10
83:2 146:13
represent 5:9
25:15,17 37:13
40:12 89:10
110:24 124:13,16
representation
5:21 7:2, 14:10
15:8 16:20 22:23
30:12,13 33:6
34:9,23 45:21
54:1159:20 61:17
62:2 64:1,8,14
66:9 70:23 91:12,
14 133:1,2,6,9
134:5,13,16
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: question - requests
represented 6:4
10:20,21 11:22,23
12:13,15 13:20
14:1,4 22:13
23:20,22 24:9,13,
15,17 25:1,19,23,
24 26:8,9,17,25
28:6,8,11, 30:24
31:4 32:10,17
40:1159:4 62:23
77:5 81:4 82:14,17
83:4,6,25 88:17
89:6,12 116:13,22
124:5 125:9,13,16
127:1,21 132:13
133:11 138:24
139:13
representing
12:21,22 24:2
28:14 29:5 31:25
56:177:17 82:22
84:1 89:14 92:22
117:5,24,25 118:3
125:20 126:2
127:3 128:1
133:18 136:5,13
140:15
Republic 98:18
request 5:1741:9,
15 44:4 46:18
52:16 58:2 100:11
104:21 111:23
112:24,25 114:18
126:8 142:2,11
requested 70:10
83:2 105:11,12
142:21
requesting 101:23
103:18 105:5
requests 42:17,20
43:8,25 44:7,11,19,
22 45:1,5,8,11,17
47:148:12,17
49:2,10,2150:2
51:7,14,24 53:14
54:13 100:1,4,6,24
101:5,11 102:7
104:5,7 105:16,21
107:24 108:23
110:14 112:11,19
113:13,20 114:5,
10,15 118:8
120:14,16,20
121:8,24 125:17
131:14 137:5
141:2,7 142:17,23
143:11
research 66:13,18,
21
residents 122:12
124:11,15
resolved 74:25
75:1,3,6,20
response 54:25
Responsible
134:10
rest 90:8 94:16
130:24
restricted 83:18
result 34:1
retained 78:7,9,
20,23 80:13,21
81:10,13,22,23
retainer 8:5
review 6:4 67:1
98:9
RICO 21:24
103:16 106:1
135:14
Ridge 9:3 11:19
12:1 13:22 20:8,13
22:19 23:23 24:14
25:19 27:23 28:10,
13 29:131:6 37:21
38:1,6 40:12 58:4,
7 62:10 68:24
70:2173:12 81:7
83:4 89:13 90:25
91:6,16 106:12,13
110:16 124:8,9,10,
12,24 125:3,20,21
126:4 127:2,6,7
128:2 133:13,23
134:1
right -hand 96:2
right -of -way
115:18
rights 129:1
road 89:22115:16
Robert 4:17 5:22
124:4
Roeder 4:21 15:20
24:5 29:8,13,20
30:1,4,8,18 41:10
43:146:14 47:7
50:18 51:12 54:19
56:2,8,11,14,22
60:4, 64:16,22
65:8 70:2 71:21
72:4 76:1,11,15
78:16 79:25 80:4,9
84:17 91:18 92:21,
25 93:3 100:18,21
104:10 105:6,24
106:25 107:4,11,14
108:4,11 111:6,9
113:22 114:6
116:16,18 119:8
120:18,21 121:3,12
122:6 123:20
126:19 131:17,24
132:7,20 136:1
137:8,13,24 138:23
139:2,23 142:18
143:6,19 145:25
146:10,12
roof 20:15,17
24:10,1126:18
28:25 40:12 50:15,
23 53:15,22 74:25
83:16,18 127:10
136:23 137:6
138:3,4
room 15:24 16:3
51:19
rules 136:12
run 39:11
running 90:11
S.E. 4:7
sandwich 136:24
scheduled 78:25
school 18:9,12,16,
18,21
Scotty 141:24
sea 106:19
search 39:5,12
searching 58:1
seat 145:17
seconds 52:24
self - righteous
131:6
separated 124:25
September 114:8
142:3
series 9:8
served 100:7
setting 127:16
settlement 38:3,6
59:21 60:1 62:4,6,
9,12 63:5,17
shakedown 104:8
sham 45:24
shame 28:16
shared 128:8
129:17
she'll 70:5 146:1
Shelley 4:4,21,25
65:1
Shelley's 59:19
ship 28:15
shot 44:4
show 55:3 73:8
77:25 78:12 99:24
108:15 121:23
126:7,16
showed 108:23
126:10
showing 51:13
88:4
shown 73:18
shows 126:14,15
sic 35:5
side 21:19,2123:4
28:11,12 31:22,24
32:2 69:5,13 77:15
91:6,8 113:17
118:14 128:15
129:3 143:24
sign 38:2 120:9,10
signature 73:15
74:18
signed 38:25 74:2,
13,16 77:5 79:4,8
80:17 126:10
signing 38:5
146:18
signs 120:2
silly 131:20
similar 124:19,24
125:3
sit 7:5 27:12 28:23
86:3
sifting 7:23 92:6
95:8
sleazy 48:20 50:5,
16 51:3,17 52:3
53:6,25 54:3,6
101:16,21 102:3
105:15
sleep- deprived
96:17
small 125:1
so- called 116:14,
18
social 10:3
solar 50:15,136:23
137:6 138:4
son 144:14,16
sort 128:22135:7,
23 136:24
sounds 14:24
85:14 104:13
105:25 106:4
108:17 125:25
space 52:17
speak 65:3 73:20
speaking 18:25
20:24 42:13
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: research -state
special 64:10,18
65:15,17 66:6
73:1178:25
specializes 94:8
specific 12:7,13
16:22 17:20,23,24
24:16,17 27:3 43:2
53:183:6 104:24
118:1,3 121:23
specifically 9:5,
21,22 15:4 20:2,5
48:10 102:22
105:3,10 115:22
124:2
specifics 30:5
34:22,52:25 75:19
83:13 117:22
127:14 133:20
speculating 9:11
speech 137:22
speeches 71:9
spelled 44:17
122:13
spend 45:10
spent 45:6
spoke 32:20 52:23
spoken 110:11
130:20
spousal 29:23
30:19 45:15
stab 25:9
stabbed 22:14
stabbing 21:13,18
22:22
Star 101:23102:10
103:12
start 58:22 100:16
144:25
started 136:11
starts 84:24
state 12:13 14:21
104:7 118:8,9
140:8
statement 46:11
70:12,17 71:1,4,11
statements 15:4
stating 69:17
stay 146:7
step 115:24
stickies 78:14
sticky 67:12
stipulation 73:10,
13 80:14
stop 132:15144:3
strategic 110:10
strategies 92:2
strategized 83:22
91:21
strategy 17:18
21:17 24:23 83:14
Stream 4:6,20
5:10 21:23 23:24
25:4,7,15 29:5
40:13,14,2141:2,
19 43:9 44:8,12
47:21, 50:24 53:22
89:11,15 90:18,24
91:7,15 100:8
101:12 102:8
103:13,23 104:5
105:2,11,22 106:3,
15,17 108:1 109:2,
9 114:11 115:4
120:3,17 123:10
124:20,25 125:3,
10,12,14 133:16,18
Street 4:8
strike 90:24
120:25 125:7
strong 11:814:25
22:5,21
stuff 58:3 111:15
stupid 69:22
subject 45:18
103:2
subjective 82:3
submit 142:10
submits 142:17
submitted 111:22
112:3,11 141:2,7
142:8
subpoena 5:12,19,
25 6:22 58:18
subpoenaed 46:20
subsequently
6:13
substantially
133:1 136:6,15,18
succeeded 81:6
sue 90:10,14
suggest 69:15
135:25
suggesting 72:11
90:10,17
suit 47:21 138:3
suits 21:2225:10
summarily 111.•5
Sunday 45:7,10
114:9
support 102:16
132:2
supposed 21:25
22:123:6
swale 115:18
Sweetapple 4:14,
17,18 5:5,9,22,23
6:16 14:6,7 16:2,
14 23:17 24:6 26:8
27:1,9 29:11,18,24
30:2,6,9,22 33:1,2,
9,11,13 34:5,13,18
36:137:17 40:16,
23 41:13 43:3,5
45:22 46:10,20
47:15,18,19 49:5,
24 50:12,20 51:10
52:7,19 53:18
54:17,2155:1
56:7,10,12,15,19
57:158:10,12
59:11,15 60:6,14,
18 64:20 65:6,9
67:16 68:14,16
69:15,24 70:6,11,
19,25 71:5,10,14,
23 73:7 76:2,7,13,
16 77:24 78:5,6,18
79:5 80:2,1182:25
83:8 84:19 85:1,3,
7,12 86:6 87:2,3,7
90:3,13 91:23
92:14,16,23 93:1,5,
12 99:23 100:22
101:9 103:7,12,20,
21,22,25 104:2,16
105:7 106:8 107:3,
8,12,21 108:6,13
109:5,24,25
110:12,21 111:7,
18,20 113:7 114:1,
7 115:1 116:17,20
119:10 120:24
121:5,14,16,18
122:14 123:21
124:4 125:6
126:22 127:24
128:6,7 129:16
130:19 131:4,12,20
132:3,9,16,19,23
135:1 136:3
137:11,18 138:1,
13,20 139:1,5,8
143:1,8,21 144:6
145:22 146:1,5,15
Sweetapple's
25:5,17 103:22
switch 56:16
swoop 76:3
swooped 75:1,3,5,
20
swooping 75:14
sword 130:17
sworn 5:217:4,9
40:7 126:25 129:5,
132:10
system 112:22
T
tab 60:1293:18
96:1
tabbed 56:17,18
58:3 146:6
table 57:24
tabs 56:315,718
57:19
tail 36:16
taking 45:23 46:3,
23 47:4 146:16
talk 12:17 15:9,19
17:17 21:124:20
34:19 82:5 117:9
137:20
talked 14:7 18:2
21:5,7 25:13 28:6
29:3 31:18 33:2
34:13,22 35:24
43:7 44:6 118:20
128:11 129:20,24
130:2 140:11
talking 10:13
11:25 19:13 20:1,
3,7 33:19 36:11
66:20 72:5,6 73:22
82:4 88:23 119:8
130:21
team 11:8 21:15
telling 14:9, 36:12
48:8
tells 88:2189:1
ten 108:3 145:2
tend 78:12
tense 81:10,25
terms 10:2511:13
19:20 44:13 48:25
138:7
testified 5:2
testify 109:14
testifying 88:1
testimony 23:13
75:23 88:16
text 118:25
therapist 128:5,7,
11,14,16,19,20,23
129:16
thing 25:8,10
30:16 70:4 86:7,
23,25 88:7 92:15
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: statement -told
126:14 128:21
131:8
things 17:422:3
51:17 89:3 102:23
115:20 116:4
thought 25:4,5,8
48:20 50:5,15
53:24 54:2,6
101:15,20 102:3
105:15 119:12
128:11 129:22,23
thousands 47:1
104:6
threatening 21:23
103:14,15,24 135:7
throw 111:5
time 4:3,1210:11,
17,11:19 13:6
15:3,21 16:9,12
17:25 18:6,24
20:1121:2,11
22:10 25:22 32:25
33:17,22 34:3,15
35:18 58:14,19
64:14,25 65:2,19
77:5,14 82:4 83:6
84:2 87:18,2188:3
89:2,9 92:1,4 93:7,
10 96:14,16,21
98:1 100:11
119:15,16 125:22
126:15 128:2
131:10,15 144:7
146:8
timeline 31:3
times 10:24 32:16
81:3 93:25 95:4,14
118:18 119:2
127:23
tired 122:22
today 5:15 7:5
8:24 9:8 27:12
34:13 86:3 95:8
102:5 103:2
107:23
told 13:12 15:8
17:15,18 24:25
25:2,16,22 26:18
31:14,15 36:6,24
37:5 44:14,21
45:4,6 53:4 63:7,
13 64:25 75:5,10,
20 76:25 102:19
105:1,5,10 113:12
115:16 117:14,17
118:19 126:13
127:9,21 132:7
140:2 142:15
143:13,19
top 56:10,20,21
57:19 60:9 61:20
66:1167:10 84:21
96:2 100:16
topic 27:16 116:7
122:19
total 52:23
town 4:6,20 5:10,
119:2 11:18 14:2
22:19 23:22,24
24:14 25:3,6,15,17
27:23 28:10,12,14
31:5,25 32:1,2
33:22 37:20 38:1,6
40:13,14,20 41:2,
IS 43:9 44:8,12,15,
16 45:12 48:17
49:1,9 50:23 53:15
58:7 62:10 63:2
64:10 65:15,17
66:13,17,2168:24
70:2172:18,22,24
73:11,17 74:1,4,12,
2181:7 83:4 87:5
89:10,12,13 90:18,
23,24 91:5,7,15
100:8 101:12
102:7 103:13,18,23
105:2,11,22 106:2,
12,15,17 107:25
109:2,8 110:15,24
114:10 115:3,7
116:3 120:17
123:10 124:8
125:4,10,12,14
128:2 133:12,15,18
135:12 136:22
137:2,5,10,12
towns 51:24
101:21,24 125:3
track 61:7
trailer 125:1
transcript 146:14
transparency
112:23
Trasher 141:2,8
travel 142:6
treated 128:4
135:9
treating 135:10
treatment 128:9
129:18 130:21,23
tree 116:4
trees 115:15,17
trial 35:1,4,9,12,16
trials 35:14
truth 76:24110:1,
3
Tuesday 78:25
turn 120:14,15
turned 137:2
type 20:20 128:21
Lei
ultimately 74:25
unanswered 46:3
uncomfortable
128:13
underpinnings
124:19,21
understand 9:12,
13 16:151:16 89:5
91:22 103:19
104:1 120:7 139:1
understanding
65:4 70:22 100:14
undertook 37:12
undetailed 69:17
uninformed 69:18
updates 14:6
17:17 31:16 33:1
upset 20:14 50:22
109:23 115:14
utter 45:24
U,
vacant 20:14
valid 70:1
Vargas 4:185:23
79:6
verified 17:3,6
verify 126:4
versus 4:6
Vespuchi 111:23
vice 139:17,20
140:7
view 45:23
violation 20:21
28:1,3,4 37:14
81:6 106:9 135:13
violations 89:3
voted 135:12
W
Wait 97:13
waive 14:1415:18
146:10
waived 15:13,15
29:12,14,15 146:18
waiving 15:6
wanted 71:11
104:25
watch 98:21
water 22:11
ways 108:11
wear 15:25
week 80:14,20,22
81:6 82:2,6 126:17
weeks 52:17
West 98:18
What'd 120:10
White 141:18,19
wife 14:22
woman 19:15,17
wonderful 19:15,
17
wondering 32:5
word 139:22
words 91:3137:15
work 12:721:24
23:8,9,10,19 27:15,
17 88:23 103:20,25
104:3 109:25
117:18,20 128:18
144:22
worked 21:10,14
22:25 23:2,3,7
25:1136:10 51:12
69:3,12 75:15,17
81:3 83:14 84:1
89:24 106:7
107:18 109:3
110:4,7,123:15,16
131:5
working 23:5,24
31:22 79:11
103:13,23 105:19
106:2,14 107:18
110:2,4,18 133:15
works 91:22 92:2
world 91:14
wrapped 36:17
write 8:19 56:20,
21,23 60:25 61:9
71:18 72:9 85:19,
2186:15 98:19
writing 45:7,11
72:14 84:6 86:5
written 38:16 57:2
72:3 81:11 139:10
wrote 8:16 57:5,
18,22 66:15 71:22,
25 80:20 87:22
98:14 99:2
Wyatt 111:25
112:4
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: top - yellow
L't
year 25:23 42:5
99:11 142:3
144:24 145:19
years 19:7 22:15
27:14 35:5,14
38:17,2158:16
88:20 89:22 92:10
145:3
yell 132:17
yelling 132:14
yellow 56:7
121:10,11,13