HomeMy Public PortalAboutRoeder Deposition Transcripts 5/20/15In The Matter Of:
CHRISTOPHER F. O'HARE v.
TOWN OF GULF STREAM
Deposition ofL 0 UIS ROEDER
May 20, 2015
DEBRA DURAN
&
A S S O C I A T E S
Registered Prnfes.sionni Reporters
P.O. Box 2288
West Palm Beach, Florida 33402
561- 313 -8000
I IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
2 CASE NO.: 502013CA017717XXXXMB AA
3
4 CHRISTOPHER F. O'HARE,
5 Plaintiff,
6 -vs-
7 TOWN OF GULF STREAM,
8 Defendant.
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10
11 VIDEOTAPED DEPOSITION OF LOUIS ROEDER, III
TAKEN AT THE INSTANCE OF THE DEFENDANT
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Wednesday, May 20, 2015
13 1:13 p.m. - 1:46 p.m.
14
5550 Glades Road
15 Suite 500
Boca Raton, Florida
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21 Reported By:
Lisa G. Simescu, RPR
22 Notary Public, State of Florida
Debra Duran & Associates
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APPEARANCES:
On behalf of the Plaintiff:
GMM /MADISON, P.A.
MARK J. HANNA, ESQ.
MARRETT HANNA, ESQ.
201 South County Road, #3272
Palm Beach, Florida 33480
(561) 223 -9990
Also on behalf of the Plaintiff:
LOUIS L. ROEDER, III
7414 Sparkling Lake Road
Orlando, Florida 32819
(407) 758 -4194
On behalf of the Defendant:
SWEETAPPLE, BROEKER & VARKAS, PL
ROBERT A. SWEETAPPLE, ESQ.
20 Southeast 3rd Street
Boca Raton, Florida 33432
(561) 392 -1230
Also Present:
Bo Cooper, Legal Graphicworks
Cynthia Bailey, Sweetapple, Broeker & Varkas, P.L.
Debra Duran & Associates
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I N D E X
WITNESS: DIRECT CROSS REDIRECT
LOUIS ROEDER, III
By Mr. Sweetapple ... 5
E X H I B I T S
NUMBER DESCRIPTION
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The videotaped deposition of LOUIS
ROEDER, III, was taken before me, Lisa G.
Simescu, RPR and Notary Public, State of
Florida at Large, at 5550 Glades Road,
Suite 500, Boca Raton, Florida, on
Wednesday, May 20, 2015, beginning at 1:13
p.m., pursuant to the Notice in said cause
for the taking of said deposition, which is
attached to the court file herein, at the
instance of the defendant in the
above - entitled cause pending in the
above -named court.
THE VIDEOGRAPHER: We're on the video
record. Today is the 20th day of May 2015.
The time is 11 -- sorry, 1:13 p.m. This is
the videotaped deposition of Louis Roeder,
III, in the matter of O'Hare verse Town of
Gulf Stream. This deposition is being held
at 5550 Glades Road, Suite 500, Boca Raton,
Florida 33431.
My name is Bo Cooper. I'm the
videographer representing Legal
Graphicworks. At this time will the
attorneys please announce their appearances
for the record.
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MR. HANNA: Mark Hanna for the
plaintiff, Christopher O'Hare.
MR. SWEETAPPLE: Robert Sweetapple on
behalf of the defendant, Town of Gulf
Stream. And, Mr. Hanna, if I could have
the exhibits or if the reporter has the
exhibits, I'll try to use the same
exhibits.
MR. HANNA: All right.
MR. SWEETAPPLE: Thank you.
Would you please state your --
THE REPORTER: Oh, wait. I haven't
sworn him yet.
MR. SWEETAPPLE: Oh, please.
WHEREUPON,
LOUIS ROEDER, III,
being by me first duly sworn to tell the whole
truth, as hereinafter certified, testified as
follows:
THE WITNESS: I do. I affirm.
DIRECT EXAMINATION
BY MR. SWEETAPPLE:
Q. Would you please state your name?
A. Louis Roeder.
Q. And what is your residence address?
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A. 7414 Sparkling Lake Road, Orlando, Florida.
Q. Uh -huh. And you are a member of the Florida
Bar?
A. Yes, I am.
Q. How long have you been a member of the
Florida Bar?
A. I think 183 or 185.
Q. And what is your educational background?
A. BA in arts and a bachelor of architecture
degree and a law degree and a MBA.
Q. Okay. And where did you get your degrees,
those degrees?
A. Bachelor of art in architecture in Rice
University, law degree and the MBA at the University
of Houston.
Q. Okay. So from you're from Texas?
A. Yes, sir.
Q. My daughter went to MRU for a couple years
before she transferred to Miami.
A. I won't hold that against you. SMU's a nice
school.
Q. I've been out there quite a bit.
How long have you known Mr. O'Hare?
A. Since before each one of us was married.
Q. So how long ago was that?
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Q.
How long have you been his lawyer? Well, you
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A.
Probably back, '71,
1970, '69, '70.
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Q.
1970, all right.
How did you know him?
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A.
He dated my wife's
best friend.
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Q.
Okay. And have
you been good friends since
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then?
Q.
First time was when 19 --
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A.
Yes, we have.
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Q.
Okay. So you've
been good friends for over
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40 years?
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A.
Yes, sir.
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Q.
Okay. Did you ever
go to school together?
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A.
No.
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Q.
All right. And
have you served as his lawyer
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for that long?
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A.
No.
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Q.
How long have you been his lawyer? Well, you
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only
became a lawyer in 180 what, 183?
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A.
183, I believe. It was 183 to 185.
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Q.
Did you represent him at that time?
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A.
No.
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Q.
When's the first time you represented him?
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A.
A few years ago.
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Q.
First time was when 19 --
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A.
I would say informally years ago, and I can't
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give
you an exact date, but probably a lot more
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formally about two and a half years ago, back in
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041108!
Q. Okay. And did you have an office down here
or an office in Orlando at the time?
A. I have an office, home office in Orlando and
I would office out of his place, his business here
in --
Q. Okay. So you have a home office in Orlando
and you come down and work out of his office on his
legal matters?
A. Yeah.
Q. And did you --
What type of legal matters --
Without disclosing what you discussed with
him, what kind of legal matters were you handling by
way of your representations to third parties or
filings with the court?
A. Initially it was business matters that didn't
deal with filings of the court, but then 2011 it
evolved.
Q. Okay. And did he start getting involved in
public records matters at that time?
A. Yeah, early on. I helped him early on. In
2011 or early 2012 was some of the first public
records requests we ever made.
Q. Okay. And when's the first time you met Joel
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1 Chandler?
2 A. I believe 2014
3 date.
I can't give you an exact
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Q.
And was he ever your paralegal?
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A.
He served in the form of a paralegal. He
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gave
advice regarding his experiences with public
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records
requests.
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Q.
Did he ever -- did you ever pay him as a
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paralegal?
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A.
I never paid him directly. If anyone paid
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him,
it was Mr. O'Hare.
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Q.
So you never hired him for your --
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Do you have a law firm or you just practice
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in your
own name?
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A.
Just practice in my own name --
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Q.
Okay.
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A.
-- and I never paid him out directly, but I
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would
sit there and take the advice. And if he had
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a bill,
he would submit it to Chris.
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Q.
Okay. So he just -- he worked for Chris
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directly?
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A.
I wouldn't say that.
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Q.
Well, have you seen any bills that he gave to
24 1 Chris?
25 1 A. No, I haven't.
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Q. And are you aware that he did bill Chris for
advice?
A. I think he did.
Q. Okay. Well, he's not a lawyer, right?
A. Who's not a lawyer?
Q. Mr. Chandler.
A. No, he's not.
Q. And he's not a paralegal?
A. I wouldn't know that.
Q. What kind of advice was Mr. Chandler giving
Mr. O'Hare?
A. I think in his experiences with public
records requests.
Q. And Mr. O'Hare was paying him for that?
A. I don't know if he was paying him for that or
what. As I said, I didn't see any bills.
Q. You never saw the bills. So how do you know
that? How do you know that Mr. O'Hare was giving
money to Mr. Chandler?
A. Just from my conversations with Mr. O'Hare
and myself.
Q. Okay. And you never spoke to Mr. Chandler
about whether or not he was giving advice to Mr.
O'Hare regarding public records requests?
A. I spoke to Mr. Chandler about giving me
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Pagc I I
advice about public records requests, about his
experiences.
Q. So you had him give you advice regarding his
experience?
A. Right.
Q. Okay. And that would include how to file
public records requests, how to set up lawsuits?
A. Not so much how to, as explain how he did it.
Q. How he did it, how he set up lawsuits?
A. No, I didn't say that. How he filed public
records requests.
Q. Well, did he tell you that he had tremendous
experience in filing public records requests and
then turning them into lawsuits all over the state?
A. No. I don't think he put it that way. He
said he had tremendous experience in filing public
records requests and he did it in such a way that if
ever it resulted in a lawsuit, he made sure that he
dotted all his is and crossed all his t's.
Q. He instructed you how to file the request so
that you could turn them into a lawsuit and win it,
right?
MR. HANNA: Objection,
mischaracterization.
THE WITNESS: That's exactly not what I
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THE REPORTER: Wait, wait, wait.
THE WITNESS: Okay, I'm sorry.
MR. HANNA: Objection,
mischaracterization.
THE WITNESS: That's what I was going
to say, is you're putting words in my
mouth. That is not what I said.
BY MR. SWEETAPPLE:
Q. Well, did he discuss with you his experience
in filing lawsuits?
A. Yes to some degree he explained his history.
Q. Okay. And what was the purpose of your
taking his advice?
A. That he knew the ins and outs of how to file
public records requests to make sure you asked for
the material properly, you got the right response
and you could get, you know, the information from
the town that you were seeking.
Q. Did he ever tell you how many public records
requests he had filed in his career?
A. No.
Q. And how many lawsuits he'd filed?
A. No.
Q. Were you aware that Mr. Chandler was
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Pagc 13
generating income by filing public records requests
and lawsuits?
A. No, I'm not aware of that.
Q. And did he ever use the word with you a "kill
shot ", that he specialized in "kill shots "?
A. I can't recall he ever used that.
Q. How to set up public records requests so it
would be a "kill shot ", you don't remember him ever
saying that or writing that?
A. No. I heard it through -- I think the first
time I heard it was in one of your motions or
complaints.
Q. Okay. And did Mr. Chandler assist you with
any of the lawsuits, any public records lawsuits?
A. I wouldn't say assist. If we had questions
about public records requests, how to file them or
had questions about cases, he knew the cases, seemed
to know the cases evidently. He knew the Sunshine
Law manual. He knew the AG's cases intimately and
he would share that information with us so we would
do our own research.
Q. All right. So he would give you information
regarding --
Did you ever file --
Did you ever review any lawsuits that were
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filed on behalf of Mr. O'Hare with Mr. Chandler?
MR. HANNA: I'm going to object. I
think you're getting into work product and
attorney - client privileged matters.
BY MR. SWEETAPPLE:
Q. Mr. Chandler -- Mr. Chandler was not your
employee, right?
A. Not an employee, no, sir.
Q. Okay. And he wasn't Mr. O'Hare's employee?
A. Not that I know of.
Q. How many times did you meet with Mr.
Chandler?
A. Meet physically? Maybe only about two or
three times.
Q. And how many times did you talk to him on the
phone?
A. Probably dozens of times.
Q. Dozens. And did you ever correspond with him
by e -mail?
A. I think a few times, yes.
Q. Okay. Do you still have those e- mails?
A. Yes, I do.
Q. That's 2014?
A. I don't know what year it is.
Q. Well, that's when you first met him, right?
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1 A. Yeah. Could have been 2014, could have been
2 2015. I think it was 2014 and not 2015.
3 Q. Okay. And did Mr. -- did Mr. Chandler ever
4 review any of the lawsuits that were prepared?
5 MR. HANNA: Again, I'm going to object.
6 1 think you're getting into work product.
7 MR. SWEETAPPLE: Well, make your
8 objection. I don't believe --
9 MR. HANNA: I'm making my objection.
10 MR. SWEETAPPLE: So you're instructing
11 him not to answer?
12 MR. HANNA: Well, he's not my client.
13 MR. SWEETAPPLE: Okay. So what's your
14 objection?
15 MR. HANNA: I'm making an objection on
16 behalf of my client Christopher O'Hare
17 involving his work product and --
18 THE WITNESS: It's his privilege so...
19 MR. HANNA: Yeah.
20 BY MR. SWEETAPPLE:
21 Q. Okay. So did, did you ever provide copies
22 of --
23 Did you ever prepare any public records
24 lawsuits from Mr. O'Hare?
25 MR. HANNA: Okay. I just want to get
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one thing. What does this have to do with
the 09/03/15 -- or 114 meeting?
MR. SWEETAPPLE: This is all related to
his relationship and it's going to go to
what he -- how close he is, what he did,
whether or not he's credible because of his
relationship.
THE WITNESS: What if I just tell you
that I'm close and I'm a very credible
person and we can go on with 09/03?
MR. SWEETAPPLE: No, because I think
that's something the judge is going to
decide based on the facts, and I'm trying
to elicit the facts.
MR. HANNA: We're here today for the
your allegations that one of us disclosed
the contents of a September 3rd, 2014
confidential meeting.
MR. SWEETAPPLE: I'm here --
MR. HANNA: And you're talking about
Joel Chandler back in 2013, 2014. Joel
Chandler had nothing to do with that
meeting.
MR. SWEETAPPLE: Well, I'll find that
out. I'm trying to ascertain generally the
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background and I don't know -- I don't -- I
haven't accused either of you of
disseminating, and I am trying to determine
who disseminated. It's clearly been
disseminated.
THE WITNESS: I think that I saw a
motion where you're alleging that it's Mr.
O'Hare, him or I.
MR. SWEETAPPLE: Someone on his behalf.
He or someone on his behalf.
THE WITNESS: I think you said his
attorneys.
MR. SWEETAPPLE: I said someone on his
behalf or his attorneys and that could
have --
MR. HANNA: Okay.
MR. SWEETAPPLE: -- been an O'Boyle Law
Firm attorney, could have been you, could
have been whoever. I don't know. I'm
trying to make discovery, and I want to
continue with my discovery.
BY MR. SWEETAPPLE:
Q. With regard to Mr. Chandler what -- from what
period of time did -- when's the first time you
communicated with Mr. Chandler and when's the last
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time?
A. I don't have any idea the first time. I
don't have any idea of the last time.
Q. Were you talking to him in 2015 in September?
A. I don't think in 2015 September, because we
haven't gotten there yet.
Q. Okay. The scope of your representation, just
to generally understand the scope of your
representation, did you ever undertake to file
public records requests for Mr. O'Hare?
A. Yes. I had filed public records requests on
his behalf.
Q. Did you prepare them for him and file them in
his name?
A. I filed for him as my client. In fact it is
stated in the public records request that I was
filing on behalf of my client. He filed his own
public records request cases too.
Q. Okay. Did you prepare those --
A. He prepared his own, I believe, but
that would be -- you're asking me what I'm doing as
an attorney.
Q. So prepared, you prepared public records
requests and filed them?
A. Yes.
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Q. For him?
A. Yes.
Q. Okay. And did you ever prepare any public
records lawsuits for him?
A. No. I -- that's getting into some privileged
and confidential.
Q. Well, I want to -- did you ever file any?
A. Did I ever file any? I think he agreed upon
them or drafted them and then we would take them
down and I would file them. If you say file, I
actually go down there and physically file them, so
I went down there and physically filed them.
Q. Okay. So he prepared lawsuits pro se and you
just took them down and filed them?
A. You're asking me my, a lot of my --
MR. HANNA: This is getting into -- I'm
going to object. It's getting into work
product.
MR. SWEETAPPLE: I'm asking you what
you did.
MR. HANNA: Attorney - client privilege.
THE WITNESS: I'm not going to tell
you. That's privileged and confidential
work product.
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BY MR. SWEETAPPLE:
Q. So how many, how many -- how many lawsuits
did you physically take down for Mr. O'Hare and
file?
A. I have no idea.
Q. And where did you file them?
A. Courthouse.
Q. At Palm Beach County?
A. Yes.
Q. So were they all cases against Gulf Stream?
A. Yes, I believe so.
Q. Okay. And do you know Martin O'Boyle?
A. Yes.
Q. And when was the first time you spoke with or
met Mr. O'Boyle?
A. I cannot even say. I think it may have been
at -- I can't remember whether it was at Mr.
O'Hare's house, but I have never really had a formal
introduction to Mr. O'Boyle.
Q. Was Mr. O'Hare -- was Mr. O'Boyle at Mr.
O'Hare's house at a time you were there?
A. I can't recall. I know he's been there, but
I can't recall whether it was a time that I've been
there.
Q. Okay. Have you ever spoken to Mr. O'Hare?
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A. Yes, I spoke to him and speak to Mr. O'Hare
all the time.
Q. I'm sorry, Mr. O'Boyle, I apologize.
Have you ever spoken to Mr. O'Boyle?
A. I think -- yes, I've spoken to him.
Q. How many times?
A. I can't recall, but very few. A handful of
times.
Q. Okay. Have you ever represented him?
A. No.
Q. Have you ever been cocounsel with the O'Boyle
Law Firm?
A. I have filed notice of appearance in a case
where the O'Boyle Law Firm was handling a case for
both Mr. O'Hare and Mr. O'Boyle, a joint case. I
think I filed a notice of appearance in that case.
I can't recall whether I actually did or not.
Q. On behalf of Mr. O'Boyle and Mr. O'Hare?
A. No, just Mr. O'Hare.
Q. And you're sure of that?
A. Yes.
Q. So you've never filed any appearance on
behalf of Mr. O'Boyle?
A. Absolutely not.
Q. And you've never provided legal advice to Mr.
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O'Boyle?
A. Absolutely not.
Q. And have you ever gone to the O'Boyle Law
offices?
A. Yes.
Q. On how many occasions?
A. Once, maybe twice.
Q. Okay. And who have you met with there?
A. Attorneys in the O'Boyle Law Firm.
Q. Which attorneys?
A. I think -- I think Nick Taylor, Giovani Mesa.
This is on different occasions. I can't remember,
you know --
Q. What about Mr. Ring?
A. Mr. Ring.
Q. Did you -- after September 3rd, 2014, did you
have any conversations with Mr. Ring?
A. That's privileged.
Q. I just want to know if you had any
conversations with him, not what they were.
A. Yes.
Q. Okay. Did you have any conversations with
Mr. Ring on September 3, 2014?
A. I can't recall.
Q. What about -- do you recall September 3, 2014
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was the day we had --
A. Yes.
Q. -- settlement meeting?
A. Yes.
Q. Okay. Do you recall if you telephoned or met
with Mr. Ring on that day?
A. I can't recall whether it was that day or the
next day, but it was like soon thereafter I think we
had a telephone conversation or met.
Q. Okay. So you had a telephone conversation
with Mr. Ring on September 4th, correct?
A. I said telephone conversation or met and I
can't remember if it was the 3rd or the 4th.
Q. Okay. So it was either the 3rd -- it was
either the day of the settlement conference or the
day after --
A. I believe so.
Q. -- that you had an interaction with Mr. Ring?
A. With the O'Boyle Law Firm. You're the one
who's pointing out Mr. Ring.
Q. Well, Mr. Ring is who you spoke to, right?
A. I spoke to some attorneys at the O'Boyle Law
Firm. I think Mr. Ring was one of them.
Q. Okay. So who was present for this meeting on
September 3rd or September 4th with the O'Boyle Law
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PaLe 24
Firm?
A. I think it was Mr. O'Hare, my client, and
representatives of the O'Boyle Law Firm. I think
Giovani Mesa, I believe, Taylor, Ring and I think
Jonathan O'Boyle was there too as a member of the
O'Boyle Law Firm. I think. I'm not sure whether he
was there or whether he was there by phone.
Q. But he was participating in this conference?
A. I believe so.
Q. And how long did this conference last?
A. I have no idea.
Q. And did you hand to anyone after
September 3rd, 2014 a copy of Exhibit 2 to this
deposition, the handwritten 09/03/14 meeting note,
settlement document?
A. That's privileged and confidential.
Q. Uh -huh. So you're asserting on your own
behalf a privilege as to whether or not you handed a
document to someone?
A. Yes.
Q. Okay. Did you have with you a copy of the
document that's marked as Exhibit 2 to this
deposition?
A. I cannot recall.
Q. Okay. Did you disclose to anyone at that
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meeting what was said at that -- at the meeting of
September 3, 2014?
A. Privileged.
MR. SWEETAPPLE: Okay. And just
certify all those for me, if you would.
(The questions were certified.)
BY MR. SWEETAPPLE:
Q. And did you make anyone at that meeting aware
that the, that there was a confidentiality agreement
to be treated as a mediation that was signed as to
the September 3, 2014 meeting?
A. Again, privileged.
Q. And what's the basis of the privilege,
because Mr. -- because Mr. --
A. I'm speaking to other attorneys that
represent Mr. O'Hare.
Q. Do you know how Mr. Ring, Mr. O'Boyle or
Airline Highway obtained a copy of the, of
Exhibit 2?
A. No idea.
Q. You didn't hand it to them?
A. No idea.
Q. Did you ever transmit by telefax or e -mail or
in any form to any -- to anyone?
A. To anyone? Anyone or anyone at the O'Boyle
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Law Firm, 'cause I want to give you an answer?
Q. Anyone ever.
A. Anyone ever... yes.
Q. Okay. And who'd you transmit it to?
A. Privileged.
Q. When did you transmit it?
A. Privileged.
Q. Okay. And you're claiming lawyer- client
privilege --
A. Yes.
Q. -- for transmitting, for scanning a document?
MR. HANNA: Also on behalf of Mr.
O'Hare, work product.
MR. SWEETAPPLE: Okay.
BY MR. SWEETAPPLE:
Q. Have you ever, have you ever stated that I
extorted anyone to anyone?
A. Have I ever stated that to anyone? No, I
don't believe so.
Q. Have you ever written that in draft or final
document?
A. As an opinion, no, I don't think so.
Q. Just stating it?
A. I said I don't think so.
Q. Have you ever heard Mr. O'Boyle say to
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someone other than an attorney of his --
A. O'Boyle or O'Hare?
Q. O'Hare. O'Boyle or O'Hare.
A. Okay. Start the question --
Q. Let's start with O'Hare. Have you ever heard
Mr. O'Hare state that he believed the town extorted
him?
A. I don't think I've ever heard him state that.
Q. Okay. Have you ever seen him write that?
A. I've never seen him write that.
Q. Have you ever seen it in a writing that he
produced?
A. I can't recall at this time.
Q. Okay.
A. You brought it up, but I can't recall ever
seeing it.
Q. Have you ever seen a writing that he's
written where he accuses me of extorting him?
A. No, I can't recall ever seeing that.
Q. Okay. Have you ever heard him say that to
any third party other than a lawyer?
A. Nope.
Q. To your knowledge have I ever made any
threats of anything that you thought was extortion
of Mr. O'Hare?
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A. I can't answer that because of
confidentiality.
Q. On the basis of what he's told you?
A. Something he's told me?
Q. Right. I'm saying other than that. I'm
saying anything you've seen.
A. Can you restate the question?
Q. Have you seen anything I've done where you
believe I've extorted Mr. O'Hare?
A. You're asking for my belief. Yeah, I believe
you extort Mr. O'Hare.
Q. Okay. How do you believe I've extorted Mr.
O'Hare?
A. I just read the definition in the statutes
here just a few moments ago and it seemed -- it
seems to me you're -- asking my opinion. Seems to
me that you have extorted him. You ask me how, I
cannot answer that, because it's confidential,
either the 09/03 meeting or it could be privileged
because I discussed it with my client.
Q. Okay. Did it have to do with the settlement
of a lawsuit?
A. Please ask me a full question. Does it have
to. It what?
Q. Does your opinion that somehow I have
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Page 29
extorted Mr. O'Hare have to do with the settlement
of a lawsuit or settlement of lawsuits?
A. In my opinion, yes.
Q. Okay. So this conduct you believe occurred
at a settlement conference that you were present at?
A. No. I believe the conduct occurred at a
scheduling conference and I think some of that
conduct occurred at a settlement conference too.
Q. Okay. were you ever present at a scheduling
conference?
A. No.
Q. Okay. And was Mr. O'Hare present at a
scheduling conference?
A. Not that I'm aware of.
Q. So everything -- some of what you're talking
about your opinion is based on hearsay.
A. Strict definition of hearsay, probably yes.
Q. Okay. Based on something Mr. Hanna told you?
A. Yes, that he was instructed to tell Mr.
O'Hare by you.
Q. He was instructed by me to tell Mr. O'Hare?
A. That's the way it was relayed to me.
Q. Okay. And how long did this meeting that
took place on September 3rd or September 4th, 2014
last?
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Page 30
A. God, you know that probably better than I do.
Probably at the time --
Q. No, no, not our meeting. I'm talking about
the one you had with the O'Boyle Law Firm.
MR. HANNA: I'm going to object,
mischaracterizes. I think you said
September 3rd meeting.
THE WITNESS: You said September 3rd.
BY MR. SWEETAPPLE:
Q. You said it was either September 3rd or
September 4th that you went over there.
A. Okay. I just want to make sure. You're
referring to --
Q. Yeah, I wouldn't have said September 3rd or
September 4th about our meeting. I know our meeting
was September 3rd. You testified that you met at
the O'Boyle Law Firm with Mr. Ring, Mr. Mesa, Mr.
Taylor and Mr. Jonathan O'Boyle; it may have been on
phone, either September 3rd or September 4th --
A. Uh -huh.
Q. -- correct?
A. Correct.
Q. How long did that meeting last?
A. I'm going to guess maybe about an hour, hour
and a half.
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Page 31
Q. And how did you go to that meeting? Were you
invited to go, or did you just go call and make an
appointment?
MR. HANNA: I'm going to object on
behalf of Mr. O'Hare, attorney - client or
work product.
BY MR. SWEETAPPLE:
Q. Did you schedule the meeting?
A. No, I did not.
Q. Okay. Do you know if Mr. O'Hare --
Did Mr. O'Hare go with you to the meeting or
was he already there?
A. He went with me to the meeting. Well, we
went to the meeting together.
Q. How many times have you gone to the O'Boyle
Law Firm with Mr. O'Hare?
A. I don't know whether that's getting into
some --
Q. How many times?
A. How many times I've been? Probably --
Yeah, speak up, I think Chris can't hear.
If you can repeat the question. I got
distracted.
Q. Yeah. How many times have you gone to the
O'Boyle Law Firm and met with someone at the O'Boyle
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Law Firm with Mr. O'Hare present?
A. Probably, if I told you like a couple of
times, both times it was with Mr. O'Hare.
Q. And do you have an employment agreement with
Mr. O'Hare?
A. I have an engagement letter.
Q. You have an engagement letter, okay. And
when did you enter into an engagement letter?
A. I think it was sometime around September or
October of 2011.
Q. Okay. And do you, do you bill him for any
legal work with regard to public records requests?
A. That's confidential.
Q. I want to know if you bill him.
A. I'm saying it's confidential.
Q. Okay. Have you been engaged by him as a
lawyer to file public records requests?
A. I have an engagement letter with him and I've
helped him file and I have filed on his behalf
public records requests.
Q. Okay. And what I'm asking is are there
instances where he has filed on his behalf pro se
where you, where you claim you have a fee
entitlement?
THE REPORTER: Where you claim what,
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I'm sorry?
MR. SWEETAPPLE: You have a fee
entitlement.
THE WITNESS: That's privileged.
BY MR. SWEETAPPLE:
Q. Is there any -- do you have any --
Are you making any, is Mr. O'Hare or you
making any claim you've performed legal services on
any cases where that hasn't been asserted in the
pleading?
A. I haven't made any claim yet.
Q. And Mr. O'Hare pays you individually or
through a company?
A. Through a company.
Q. Okay. Which company are you engaged by?
A. Pineapple Grove.
Q. And do you get paid weekly, monthly?
A. About twice a month.
Q. Do you have any other clients besides Mr.
O'Hare?
A. Just informal clients.
Q. No other paying clients.
A. Informal clients. Some pay, some don't.
Q. Okay. So Mr. O'Hare is your main client?
A. Yes.
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Page 34
Q. Okay. He's your source of livelihood?
A. I wouldn't go that far.
Q. Do you have other, other clients in your
practice that pay for your practice or is he your
primary --
A. I think I already said he's my primary.
Q. Okay. What percentage of your practice --
A. That's confidential. Come on, Bob, you know.
Q. No.
A. Yes, it is.
Q. Percentage goes to credibility. It's not --
you have to disclose it. You have to disclose it to
the bar. You have to disclose it to your insurance
carrier.
A. If the Bar asks me, I'll disclose it to them,
Bob. Until they do, I'm sorry, it's privileged.
Q. I want to know in terms of your credibility.
MR. HANNA: Bob --
THE WITNESS: I've already given my
answer. Can we go on to another question?
MR. SWEETAPPLE: No, I want to know
what percentage of your income --
THE WITNESS: I refuse to answer
because of privilege.
MR. SWEETAPPLE: -- comes from Mr.
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O'Hare's company.
THE WITNESS: I refuse to answer.
MR. HANNA: He's not answering it. You
want to move on.
MR. SWEETAPPLE: Okay. I'll certify
it.
THE WITNESS: Please.
(The question was certified.)
BY MR. SWEETAPPLE:
Q. And how long has Mr. O'Hare been your primary
source of income?
MR. HANNA: I'm going to object.
Mischaracterization.
BY MR. SWEETAPPLE:
Q. Is he your primary source of income?
MR. HANNA: Object, asked and answered.
BY MR. SWEETAPPLE:
Q. Is he your primary source of income?
A. So far, yes.
Q. And how long has he been your primary source
of income?
A. Last year to two years.
Q. And how many hours a week do you work for Mr.
O'Hare?
A. That's privileged, I'm sorry.
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Q. Why is that privileged? Tell me the nature
of that privilege so when we go to court I can, I
can have some idea what you're going to argue. Is
it lawyer- client? Is it work product?
MR. HANNA: He doesn't have to and
you're also -- he also testified that he
does more broad legal work for Mr. O'Hare.
BY MR. SWEETAPPLE:
Q. How many hours a week do you typically work
for Pineapple Grove or Mr. O'Hare?
A. I already refused once to answer and --
Q. Are you a full -time employee?
A. No, sir, I'm not.
Q. Okay. Do you work less than 30 hours a week
for him?
A. I'm not answering that.
Q. Okay. Do you render him bills for your time?
A. I'm not answering, it's privileged.
Q. Whether or not you render him bills is
privileged? What is that a lawyer- client privilege
or a work product privilege or both?
A. Both.
Q. Okay. And did you have any --
Did you review the complaint that was filed
by Mr. Ring on behalf of Mr. O'Boyle and Airline
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Page 37
Highway that made reference to the September 3rd,
2014 settlement conference?
A. Only through your motion.
Q. Did you have any subsequent meetings at the
O'Boyle Law Firm after this meeting of September 3rd
or September 4th?
A. No.
Q. Did you have any e -mails or phone
conversations with them at any time after that
September 3rd or September --
A. Privileged.
Q. -- 4th meeting?
Just want to know if you had any, not what
the contents are.
A. Privileged. Same basis on which you felt you
objected to answer questions about your employment
with the town and whether or not you represented the
town. Every answer was attorney work product.
That's attorney work product for me too.
Q. Okay.
A. It's no different.
Q. All right. So you're not going to answer
whether or not you have any such writings so that I
could then subpoena them and then you can assert a
privilege under the law? I just want to know if
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they exist.
A. I'm saying privileged. The fact if I
acknowledge they exist, then I'm giving away a
representation.
Q. So did you bring any communications with you
pursuant to the subpoena you were served with?
A. There are none --
Q. So you have --
A. -- that aren't privileged.
Q. There are none that aren't privileged.
Did you bring any documents with you to
assert a privilege over?
A. No.
Q. Do you have documents that are responsive to
the subpoena?
A. Yes.
Q. Then why didn't you bring them?
A. Because they're privileged.
Q. But that doesn't excuse you from bringing
them. You have to identify --
You're a lawyer, right?
A. You know I am.
Q. Okay. Have you, have you ever practiced in
court?
A. Yes.
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Page 39
Q. Have you ever tried a case?
A. No.
Q. Have you ever subpoenaed anyone for
deposition?
A. No.
Q. Have you ever taken a deposition?
A. Yes.
Q. Okay. Are you aware that when you're
subpoenaed for documents that you still have to
bring them to the deposition and then identify on
the record what you assert is privileged in Florida?
A. I've given you my answer, sir.
Q. Okay. So what documents do you have, what
e- mails, text messages or other written
communications do you have concerning the settlement
conference?
A. Nothing that is not privileged.
Q. That's for the judge to decide, not for you
to decide. Can you tell me what documents you have
so I can then get them, we can get the court to
examine them in camera and we can have the judge
adjudicate it rather than you?
A. You have my answer.
Q. So the answer is you're not going to answer?
A. I already answered.
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Q. It's privileged. You've decided it's
privileged; you're not going to tell me what
documents you physically have.
A. No, sir.
Q. Is that correct, you're not going to tell me?
A. It's privileged.
Q. Okay.
MR. SWEETAPPLE: Well, I'm going to
suspend the deposition, and I'm going to
move for an order compelling and for an
award of attorney fees and costs based on
these obstructionistic actions by Mr.
Roeder, who is an attorney. All right.
THE REPORTER: Read or waive for this
portion?
MR. HANNA: He'll read.
THE VIDEOGRAPHER: Time is 1:46.
Deposition is concluded.
(The reading and signing of this
deposition is not waived.)
Witness excused.
(The deposition was concluded at 1:01
p.m.)
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Page 41
CERTIFICATE OF OATH
THE STATE OF FLORIDA:
COUNTY OF PALM BEACH:
I, the undersigned authority, certify
that LOUIS ROEDER, III personally appeared before me
and was duly sworn.
WITNESS my hand and official seal this
5th day of June 201S..�/�
�d. x1,�„uoac
Lisa G. Simescu, RPR
Notary Public - State of Florida
My Commission No.: EE209439
Expires: July 13, 2016
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Page 42
CERTIFICATE
I, Lisa G. Simescu, Notary Public in and
for the State of Florida at Large, do hereby certify
that the foregoing deposition was taken before me in
this cause at the time and place and in the presence
of counsel as shown herein; that the foregoing pages
contain a true and correct transcription of the
testimony of said witness.
I hereby certify that I am neither
attorney for any party, nor am I related to or
employed by any attorney or party connected with the
action, nor am I financially interested in the
action.
5th day of June 2015.
Lisa G. Simescu, RPR
Notary Public State of Florida at Large
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Page 43
RULE 1.310 FLORIDA RULES OF CIVIL PROCEDURE
PROVIDES:
(e) Any changes in form or substance which
the witness desires to make shall be entered upon
the deposition by the officer with a statement of
the reasons given by the witness for making them.
PAGE LINE CHANGE REASON
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Page 44
C E R T I F I C A T E
THE STATE OF FLORIDA)
COUNTY OF PALM BEACH)
I hereby certify that I have read the
foregoing deposition by me given, and that the
statements contained herein are true and correct to
the best of my knowledge and belief, with the
exception of any corrections or notations made on
the errata sheet, if one was executed.
Dated this day of 2015.
LOUIS ROEDER, III
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Page 45
June 5, 2015
Louis Roeder, III, Esq.
In re: O'Hare v. Town of Gulf Stream
Videotaped deposition testimony of Louis Roeder, III
given on May 20, 2015
The referenced transcript has been completed
and awaits reading and signing. Please call our
office at the below - listed number between the hours
of 9:00 a.m. - 3:00 p.m., Monday through Friday to
schedule an appointment to come to our office and
read and sign the transcript. If desired, you may
also opt to waive signature. if so, sign your name
at the bottom and mail to our office to be attached
to the original transcript.
If the transcript is not reviewed and signed
within 30 days, the original, which has been sent to
the ordering attorney, may be filed with the Clerk
of the Court.
Very truly yours,
sa G. Simescu, RPR
I hereby waive my signature:
CC: All counsel of record
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
0
09/03 16:10 28:19
09/03/14 24:14
09/03/15 16:2
1
11 4:15
14 16:2
19 7:22
1970 7:1,2
1:01 40:22
1:13 4:6,15
1:46 40:17
3
2 24:13,22 25:19
20 4:6
2011 8:1,18,23
32:10
2012 8:23
2013 16:21
2014 9:2 14:23
15:1,2 16:17,21
22:16,23,25 24:13
25:2,1129:24 37:2
2015 4:6,1415:2
18:4,5
20th 4:14
k'
3 22:23,2525:2,11
30 36:14
33431 4:20
3rd 16:1722:16
23:13,14,25 24:13
29:24 30:7,8,10,14,
16,19 37:1,5,10
4
40 7:8
4th 23:11,13,25
29:24 30:11,15,19
37:6,12
5
500 4:5,19
5550 4:4,19
6
69 7:1
7
70 7:1
71 7:1
7414 6:1
8
80 7:16
83 6:77:16,17
85 6:7 7:17
A
above - entitled
4:11
above -named
4:12
Absolutely 21:24
22:2
accused 17:2
accuses 27:18
acknowledge 38:3
actions 40:12
address 5:25
adjudicate 39:22
advice 9:6,1810:2,
10,23 11:1,3 12:14
21:25
affirm 5:20
AG'S 13:19
agreed 19:8
agreement 25:9
32:4
Airline 25:18
36:25
allegations 16:16
alleging 17:7
announce 4:24
answering 35:3
36:16,18
apologize 21:3
appearance
21:13,16,22
appearances 4:24
appointment 31:3
architecture 6:9,
13
argue 36:3
art 6:13
arts 6:9
ascertain 16:25
asks 34:15
assert 37:2438:12
39:11
asserted 33:9
asserting 24:17
assist 13:13,15
attached 4:9
attorney 17:18
18:22 27:137:18,
19 40:11,13
attorney - client
14:4 19:2131:5
attorneys 4:24
17:12,14 22:9,10
23:22 25:15
award 40:11
aware 10:112:25
13:3 25:8 29:14
39:8
B
BA 6:9
bachelor 6:9,13
back 7:1,2516:21
background 6:8
17:1
bar 6:3,634:13,15
based 16:13 29:16,
18 40:11
basis 25:13 28:3
37:15
Beach 20:8
beginning 4:6
behalf 5:414:1
15:16 17:9,10,14
18:12,17 21:18,23
24:18 26:12 31:5
32:19,22 36:25
belief 28:10
believed 27:6
bill 9:19 10:1
32:11,14
bills 9:2310:16,17
36:17,19
bit 6:22
Bo 4:21
Bob 34:8,16,18
Boca 4:5,19
bring 38:5,11,17
39:10
bringing 38:19
broad 36:7
brought 27:15
business 8:5,17
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: 09/03-concluded
C
call 31:2
camera 39:21
career 12:21
carrier 34:14
case 21:13,14,15,
16 39:1
cases 13:17,18,19
18:18 20:10 33:9
certified 5:18 25:6
35:8
certify 25:5 35:5
Chandler 9:1
10:6,10,19,22,25
12:25 13:13 14:1,
6,12 15:3 16:21,22
17:23,25
Chris 9:19,20,24
10:131:21
Christopher 5:2
15:16
claim 32:23,25
33:8,11
claiming 26:8
client 15:12,16
18:15,17 24:2
28:20 33:24
clients 33:19,21,
22,23 34:3
close 16:5,9
cocounsel 21:11
communicated
17:25
communications
38:5 39:15
company 33:13,
14,15 35:1
compelling 40:10
complaint 36:24
complaints 13:12
concluded 40:18,
22
conduct 29:4,6,8
conference 23:15
24:8,10 29:5,7,8,
10,13 37:2 39:16
confidential 16:18
19:6,23 24:16
28:18 32:13,15
34:8
confidentiality
25:9 28:2
contents 16:17
37:14
continue 17:21
conversation
23:9,10,12
conversations
10:20 22:17,20,22
37:9
Cooper 4:21
copies 15:21
copy 24:13,21
25:18
correct 23:11
30:21,22 40:5
correspond 14:18
costs 40:11
County 20:8
couple 6:18 32:2
court 4:9,12 8:16,
18 36:2 38:24
39:20
Courthouse 20:7
credibility 34:11,
17
credible 16:6,9
crossed 11:19
D
date 7:24 9:3
dated 7:3
daughter 6:18
day 4:1423:1,6,7
8,15,16
deal 8:18
decide 16:13
39:18,19
decided 40:1
defendant 4:10
5:4
definition 28:14
29:17
degree 6:10,14
12:12
degrees 6:11,12
deposition 4:1,8,
16,18 24:14,23
39:4,6,10 40:9,18,
20,22
determine 17:3
DIRECT 5:21
directly 9:10,17,21
disclose 24:25
34:12,13,15
disclosed 16:16
disclosing 8:13
discovery 17:20,
21
discuss 12:10
discussed 8:13
28:20
disseminated
17:4,5
disseminating
17:3
distracted 31:23
document 24:15,
19,22 26:11,21
documents 38:11,
14 39:9,13,19 40:3
dotted 11:19
dozens 14:17,18
draft 26:20
drafted 19:9
duly 5:17
E
e-mail 14:19 25:23
e -mails 14:2137:8
39:14
early 8:22,23
educational 6:8
elicit 16:14
employee 14:7,8,9
36:12
employment 32:4
37:16
engaged 32:16
33:15
engagement 32:6,
7,8,18
enter 32:8
entitlement 32:24
33:3
evidently 13:18
evolved 8:19
exact 7:24 9:2
EXAMINATION
5:21
examine 39:21
excuse 38:19
excused 40:21
Exhibit 24:13,22
25:19
exhibits 5:6,7,8
exist 38:1,3
experience 11:4,
13,16 12:10
experiences 9:6
10:12 11:2
explain 11:8
explained 12:12
extort 28:11
extorted 26:17
27:6 28:9,12,17
29:1
extorting 27:18
extortion 27:24
F
fact 18:1538:2
facts 16:13,14
fee 32:23 33:2
fees 40:11
felt 37:15
file 4:9 11:6,20
12:15 13:16,24
18:9,13 19:7,8,10,
1120:4,6 32:17,19
filed 11:1012:21,
23 14:1 18:11,15,
17,24 19:12,14
21:13,16,22 32:19,
22 36:24
filing 11:13,16
12:11 13:1 18:17
filings 8:16,18
final 26:20
find 16:24
firm 9:13 17:18
21:12,14 22:9
23:19,23 24:1,396
26:130:4,17
31:16,25 32:137:5
Florida 4:4,5,20
6:1,2,6 39:11
form 9:5 25:24
formal 20:18
formally 7:25
friend 7:3
friends 7:4,7
full 28:23
full -time 36:12
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: conduct -hear
G
gave 9:6,23
generally 16:25
18:8
generating 13:1
Giovani 22:11
24:4
give 7:24 9:2 11:3
13:22 26:1
giving 10:10,18,23,
25 38:3
Glades 4:4,19
God 30:1
good 7:4,7
Graphicworks
4:23
Grove 33:16 36:10
guess 30:24
Gulf 4:18 5:4
20:10
M
half 7:25 30:25
hand 24:12 25:21
handed 24:18
handful 21:7
handling 8:14
21:14
handwritten
24:14
Hanna 5:1,5,9
11:23 12:4 14:2
15:5,9,12,15,19,25
16:15,20 17:16
19:16,2126:12
29:18 30:5 31:4
34:18 35:3,12,16
36:5 40:16
He'll 40:16
hear 31:21
heard 13:10,11
26:25 27:5,8,20
hearsay 29:16,17
held 4:18
helped 8:2232:19
hereinafter 5:18
Highway 25:18
37:1
hired 9:12
history 12:12
hold 6:20
home 8:4,7
hour 30:24
hours 35:23 36:9,
14
house 20:18,21
Houston 6:15
I
is 11:19
idea 18:2,3 20:5
24:1125:20,22
36:3
Identify 38:20
39:10
III 4:2,175:16
include 11:6
income 13:134:22
35:11,15,18,21
individually
33:12
informal 33:21,23
informally 7:23
information
12:18 13:20,22
Initially 8:17
Ins 12:15
Instance 4:10
Instances 32:22
instructed 11:20
29:19,21
instructing 15:10
insurance 34:13
Interaction 23:18
intimately 13:19
Introduction
20:19
Invited 31:2
involved 8:20
involving 15:17
J
Joel 8:25 16:21
joint 21:15
Jonathan 24:5
30:18
judge 16:1239:18,
21
K
kill 13:4,5,8
kind 8:1410:10
knew 12:15 13:17,
18,19
knowledge 27:23
L
Lake 6:1
Large 4:4
law 6:10,149:13
13:19 17:17 21:12,
14 22:3,9 23:19,22,
25 24:3,6 26:1
30:4,17 31:16,25
32:137:5,25
lawsuit 11:18,21
28:22 29:2
lawsuits 11:7,9,14
12:11,23 13:2,14,
25 15:4,24 19:4,13
20:2 29:2
lawyer 7:12,15,16
10:4,5 27:2132:17
38:21
lawyer - client 26:8
36:4,20
legal 4:22 8:9,12,
14 21:25 32:12
33:8 36:7
letter 32:6,7,8,18
Lisa 4:2
livelihood 34:1
long 6:5,23,25
7:13,15 24:10
29:23 30:23 35:10,
20
lot 7:24 19:15
Louis 4:1,165:16,
24
M
made 8:2411:18
27:23 33:1137:1
main 33:24
make 12:16 15:7
17:20 25:8 30:12
31:2
making 15:9,15
33:7,8
manual 13:19
Mark 5:1
marked 24:22
married 6:24
Martin 20:12
material 12:17
matter 4:17
matters 8:9,12,14,
17,21 14:4
MBA 6:10,14
mediation 25:10
meet 14:11,13
meeting 16:2,18,
23 23:3,24 24:14
25:1,8,1128:19
29:23 30:3,7,15,23
31:1,8,1 1,13,14
37:5,12
meetings 37:4
member 6:2,5
24:5
Mesa 22:1124:4
30:17
messages 39:14
met 8:25 14:25
20:15 22:8 23:5,9,
12 30:16 31:25
Miami 6:19
mischaracterizati
on 11:24 12:5
35:13
mischaracterizes
30:6
moments 28:15
money 10:19
month 33:18
monthly 33:17
motion 17:737:3
motions 13:11
mouth 12:8
move 35:440:10
MRU 6:18
ro
nature 36:1
nice 6:20
Nick 22:11
Notary 4:3
note 24:14
notice 4:721:13,16
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: heard -outs
L7
O'boyle 17:17
20:12,15,19,20
21:3,4,11,14,15,18,
23 22:1,3,9 23:19,
22,25 24:3,5,6
25:17,25 26:25
27:2,3 30:4,17,18
31:15,25 36:25
37:5
O'hare 4:17 5:2
6:23 9:11 10:11,
14,18,20,24 14:1
15:16,24 17:8
18:10 20:3,20,25
21:1,15,18,19 24:2
25:16 26:13 27:2,
3,5,6,25 28:9,11,13
29:1,12,20,2131:5,
10,11,16 32:1,3,5
33:7,12,20,24
35:10,24 36:7,10
O'hare's 14:9
20:18,2135:1
object 14:2 15:5
19:17 30:5 31:4
35:12,16
objected 37:16
objection 11:23
12:4 15:8,9,14,15
obstructionistic
40:12
obtained 25:18
occasions 22:6,12
occurred 29:4,6,8
October 32:10
office 8:2,3,4,5,7,8
offices 22:4
opinion 26:22
28:16,25 29:3,16
order 40:10
Orlando 6:1 8:3,4,
7
outs 12:15
P
p.m. 4:7,15 40:23
paid 9:10,1733:17
Palm 20:8
paralegal 9:4,5,9
10:8
participating 24:8
parties 8:15
party 27:21
pay 9:8 33:23 34:4
paying 10:14,15
33:22
pays 33:12
pending 4:11
percentage 34:7,
11,22
performed 33:8
period 17:24
person 16:10
phone 14:1624:7
30:19 37:8
physically 14:13
19:11,12 20:3 40:3
Pineapple 33:16
36:10
place 8:5 29:24
plaintiff 5:2
pleading 33:10
pointing 23:20
portion 40:15
practice 9:13,15
34:4,7
practiced 38:23
prepare 15:23
18:13,19 19:3
prepared 15:4
18:20,23 19:13
present 23:24
29:5,9,12 32:1
primary 34:5,6
35:10,15,18,20
privilege 15:18
19:2124:18 25:13
26:9 34:24 36:2,
20,2137:25 38:12
privileged 14:4
19:5,23 22:18
24:16 25:3,12
26:5,7 28:19 33:4
34:16 35:25 36:1,
18,20 37:11,15
38:2,9,10,18 39:11,
17 40:1,2,6
pro 19:13 32:22
produced 27:12
product 14:315:6,
17 19:18,24 26:13
31:6 36:4,21
37:18,19
properly 12:17
provide 15:21
provided 21:25
public 4:3 8:21,23
9:6 10:12,24 11:1,
7,10,13,16 12:16,
20 13:1,7,14,16
15:23 18:10,11,16,
18,23 19:3 32:12,
17,20
purpose 12:13
pursuant 4:7 38:6
put 11:15
putting 12:7
Q
question 27:4
28:7,23 31:22
34:20 35:8
questions 13:15,
17 25:6 37:16
R
Raton 4:5,19
read 28:14 40:14,
16
reading 40:19
recall 13:6 20:22,
23 21:7,17 22:24,
25 23:5,7 24:24
27:13,15,39
record 4:14,25
39:11
records 8:21,24
9:7 10:13,24 11:1,
7,11,13,1712:16,
20 13:1,7,14,16
15:23 18:10,11,16,
18,23 19:4 32:12,
17,20
reference 37:1
referring 30:13
refuse 34:23 35:2
refused 36:11
regard 17:23
32:12
related 16:3
relationship 16:4,
7
relayed 29:22
remember 13:8
20:17 22:12 23:13
render 36:17,19
repeat 31:22
reporter 5:6,12
12:2 32:25 40:14
represent 7:18
25:16
representation
18:7,9 38:4
representations
8:15
representatives
24:3
represented 7:20
21:9 37:17
representing 4:22
request 11:20
18:16,18
requests 8:24 9:7
10:13,24 11:1,7,11,
13,17 12:16,21
13:1,7,16 18:10,11,
24 32:12,17,20
research 13:21
residence 5:25
response 12:17
responsive 38:14
restate 28:7
resulted 11:18
review 13:2515:4
36:24
Rice 6:13
Ring 22:14,15,17,
23 23:6,11,18,20,
21,23 24:4 25:17
30:17 36:25
Road 4:4,196:1
Robert 5:3
Roeder 4:2,16
5:16,24 40:13
RPR 4:3
scanning 26:11
schedule 31:8
scheduling 29:7,9,
13
school 6:217:10
scope 18:7,8
seeking 12:19
September 16:17
18:4,5 22:16,23,25
23:11,25 24:13
25:2,1129:24
30:7,8,10,11,14,15,
16,19 32:9 37:1,5,
6,10
served 7:12 9:5
38:6
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586
Index: p.m- .subpoenaed
services 33:8
set 11:7,9 13:7
settlement 23:3,15
24:15 28:2129:1,
21518 37:2 39:15
share 13:20
shot 13:5,8
shots 13:5
signed 25:10
signing 40:19
Simescu 4:3
sir 6:17 7:9 14:8
36:13 39:12 40:4
sit 9:18
SMU'S 6:20
source 34:135:11,
15,18,20
Sparkling 6:1
speak 21:131:21
speaking 25:15
specialized 13:5
spoke 10:22,25
20:14 21:123:21,
22
spoken 20:25 21:4,
5
start 8:2027:4,5
state 4:3 5:11,23
11:14 27:6,8
stated 18:16 26:16,
18
stating 26:23
statutes 28:14
Stream 4:18 5:5
20:10
Strict 29:17
submit 9:19
subpoena 37:24
38:6,15
subpoenaed 39:3,
9
Index: subsequent —years
subsequent 37:4
today 4:14 16:15
when's 7:20 8:25
Suite 4:5,19
told 28:3,4 29:18
17:24,25
Sunshine 13:18
32:2
who'd 26:4
suspend 40:9
town 4:175:4
wife's 7:3
12:19 27:6 37:17,
Sweetapple 5:3,
18
win 11:21
10,14,2212:914:5
transferred 6:19
word 13:4
15:7,10,13,2016:3,
11,19,24 17:9,13,
transmit 25:23
words 12:7
17,2219:1920:1
26:4,6
work 8:814:3
25:4,726:14,15
transmitting
15:6,1719:17,24
30:9 31:7 33:2,5
26:11
26:13 31:6 32:12
34:21,25 35:5,9,14,
35:23 36:4,7,9,14,
17 36:8 40:8
treated 25:10
21 37:18,19
sworn 5:13,17
tremendous
worked 9:20
11:12,16
write 27:9,10
T
truth 5:18
writing 13:9
turn 11:21
27:11,17
taking 4:8 12:14
turning 11:14
writings 37:23
talk 14:15
type 8:12
written 26:20
talking 16:20 18:4
27:18 39:14
29:15 30:3
typically 36:9
Taylor 22:1124:4
V
30:18
U
Uh -huh 6:224:17
telefax 25:23
year 14:2435:22
telephone 23:9,10,
30:20
years 6:187:8,21,
12
understand 18:8
23,25 35:22
telephoned 23:5
undertake 18:9
terms 34:17
University 6:14
testified 5:18
30:16 36:6
V
Texas 6:16
text 39:14
verse 4:17
thing 16:1
video 4:13
thought 27:24
W
threats 27:24
time 4:15,23 7:18,
wait 5:12 12:2
20,22 8:3,21,25
waive 40:14
13:11 17:24 18:1,
2,3 20:14,21,23
waived 40:20
21:2 27:13 30:2
36:1737:940:17
Wednesday 4:6
times 14:11,14,15,
week 35:2336:9,
17,20 21:6,8 31:15,
14
19,20,24 32:3
weekly 33:17
Debra Duran & Associates
Phone 561.313.8000 Fax 561.835.8586