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HomeMy Public PortalAboutSweetapple Transcript 5/27/161 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:14-CV-81250-KAM MARTIN E. O'BOYLE, Plaintiff, Vs. ROBERT A. SWEETAPPLE and MAYOR SCOTT MORGAN, Defendants. VA DEPOSITION OF ROBERT SWEETAPPLE Taken on behalf of the Plaintiff VOLUME I PAGES 1 - 175 DATE TAKEN: Friday, May 27, 2016 TIME: 9:00 a.m. - 7:00 p.m. PLACE: THE OFFICE OF DAUGHTERS REPORTING 1515 North Federal Highway Suite 300 Boca Raton, Florida 33432 Examination of the witness taken before: LISA GREENWELL, Merit Reporter DAUGHTERS REPORTING, INC. 934 North University Drive Suite 224 Coral Springs, Florida 33071 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCE FOR THE PLAINTIFF MARTIN E. O'BOYLE, pro se 1280 West Newport Center Drive Deerfield Beach, Florida 33442 APPEARANCE FOR THE DEFENDANT ROBERT A. SWEETAPPLE JOSHUA A. GOLDSTEIN, Esquire THE LAW OFFICES OF COLE, SCOTT & KISSANE, P.A. 1645 Palm Beach Lakes Boulevard Second Floor West Palm Beach, Florida 33401 APPEARANCE FOR THE DEFENDANT Town of Gulf Stream JEFFREY L. HOCHMAN, Esquire THE LAW OFFICES OF JOHNSON, ANSELMO, MURDOCH, BURKE PIPER & HOCHMAN, P.A. 2455 East Sunrise Boulevard Suite 1000 Fort Lauderdale, Florida 33304 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 I 1 I -N -D -E -X 2 3 DEPOSITION OF ROBERT A. SWEETAPPLE Page No. 4 5 Direct Examination by Mr. O'Boyle 4 6 7 8 9 10 E -X -H -I -B -I -T -S 11 Plaintiff Page 12 No. 1 Second Amended Complaint 174 13 14 15 16 CERTIFIED QUESTIONS 17 Page Line 18 11 24 19 19 19 20 28 19 21 44 8 22 122 12 23 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 I 1 WHEREUPON, 2 ROBERT A. SWEETAPPLE 3 having been first duly sworn, testified upon his oath as 4 follows: 5 THE WITNESS: Yes, I do. 6 DIRECT EXAMINATION 7 BY MR. O'BOYLE: 8 Q. Mr. Sweetapple, my name is Martin O'Boyle and I 9 am here today to take your deposition in a matter styled 10 Martin O'Boyle versus Robert Sweetapple and the Town of 11 Gulf Stream. 12 Are you familiar with that matter? 13 A. Only to have read the pleadings. I am not going 14 to discuss my work product with regard to that. 15 Q. And what work product would that be? 16 A. In terms of the lawsuit against me. 17 Q. Hm-hum. 18 A. Discussions with counsel and other matters that I 19 acquired into and investigative. 20 Q. Well, discussions with counsel I can certainly 21 understand that, assuming they were in connection with 22 the litigation. 23 But what other matters? 24 A. I'm sorry, what do you mean "what other matters"? 25 Q. Well, you said you're not going to discuss your Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 G 1 work product? 2 A. I'm not going to discuss anything I did with 3 regard to my defense in that case. 4 Q. That's fine. Then you raised the word "work 5 product". 6 A. Um -hum. 7 Q. What do you mean by "work product" in the context 8 of this litigation? 9 MR. GOLDSTEIN: Object to form. 10 THE WITNESS: I am not going to give you my 11 legal opinions here. I'm here to testify as to 12 facts. 13 If you have a fact question, but I am not 14 going to explain the law to you or give you my 15 legal opinion, I'm sorry. 16 BY MR. O'BOYLE: 17 Q. What facts have led you to believe that whatever 18 it is that I've done, which -- in connection with what 19 you're calling work product are, indeed, work product? 20 MR. GOLDSTEIN: Object to form. 21 THE WITNESS: Having attended law school and 22 practiced law school for 37 years. 23 BY MR. O'BOYLE: 24 Q. So, that makes you infallible? 25 MR. GOLDSTEIN: Form. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 0 1 THE WITNESS: Are you asking me my opinion 2 about infallibility? 3 BY MR. O'B0YLE: 4 Q. No. I'm asking you a question of fact. 5 A. Well, I don't think that's a matter of fact. I 6 don't think anyone's infallible. 7 You're trying to ask my opinion about things and 8 I'm here to answer fact questions, Mr. O'Boyle. 9 Q. Okay. It would be helpful if you would not read 10 my mind and not tell me what I'm thinking. I'd 11 appreciate that. 12 A. I don't think that's what I'm doing. I'm here to 13 answer your questions. 14 Q. You just said I think, that many applies, but 15 we'll move on. That's fine. 16 MR. GOLDSTEIN: Move to strike. 17 BY MR. O'B0YLE: 18 Q. Give me a little background, if you could, on 19 yourself? 20 A. What would you like to know? 21 Q. Your education. Let's start with high school? 22 A. He attended Nova High School in Fort Lauderdale, 23 Florida. 24 Q. And? 25 A. What else would you like to know? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 7 1 Q. I just said, let's start with your high school. 2 A. I graduated from high school. Do you want to 3 know where I went to college? 4 Q. That would be good. 5 A. You attended Colgate University in Hamilton, New 6 York. 7 Q. I see. Is that where you got your law degree? 8 A. No, it isn't. 9 Q. Okay. Can you share with me where you got your 10 law degree? 11 A. Yes, sir. At the University of Florida. 12 Q. I see. And are you an LLM? 13 A. No. 14 Q. Do you have a boat? 15 A. Do I have a boat? That's a personal matter. But 16 yes, I do have a boat. I don't know why you want to 17 know that, but I do have a boat. 18 Q. Okay. Mr. Sweetapple, why I want to know things 19 is my work product. 20 A. Well, I'm not going to -- 21 MR. GOLDSTEIN: Hold on. Mr. O'Boyle, I 22 just remind you of the Judge's prior orders 23 regarding keeping things to the relative facts 24 and issues in this case. 25 I will certainly give you some leeway. I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 J 1 understand you're just trying to inquire as to 2 background information, etc. 3 But, you know, I am not sure you're 4 questioning my client on his boat has any 5 relevance to this proceedings. 6 MR. O'BOYLE: I understand you're not quite 7 sure and I appreciate that. And thank you for 8 the lesson. 9 BY MR. O'B0YLE: 10 Q. What's the name of the boat? 11 A. The large boat is called Alpha Dog. 12 Q. And I assume you have a smaller boat? 13 A. Yeah, doesn't have a name on it. 14 Q. I see. And I never heard that phrase Alpha Dog. 15 Is there some meaning to it? 16 A. I am not going to discuss my personal discussions 17 with friends, but that was the name I was given in 18 college, yes. 19 Q. You, personally, were called Alpha Dog? 20 A. Yes. 21 Q. I see. Okay. And from there, you passed it onto 22 your boat, would that be correct? 23 A. Passed it onto my boat? 24 Q. Yeah. It went from you and now it's the name of 25 your boat, correct? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 I 1 A. Well, that is the name on my boat, yes. 2 Q. Okay. And what I was asking is, it went from you 3 to your boat, right? 4 In other words, it didn't make a stops in 5 between? 6 A. I don't understand your question. 7 Q. Okay. 8 MR. GOLDSTEIN: Asked and answered. 9 MR. O'BOYLE: We'll just move on. 10 BY MR. O'BOYLE: 11 Q. Where do you live? 12 A. In Boca Raton. 13 Q. How long have you lived there? 14 A. Since 1986, so 30 years. 15 Q. Same house? 16 A. No. 17 Q. Okay. Your present house, how long have you 18 lived there? 19 A. I would say ten -- ten -and -a -half years, almost 20 11 years. 21 Q. And I assume that you lived there with your 22 family? 23 A. I'm not going to discuss my personal life with 24 you, Mr. O'Boyle. That's my private information. 25 You already asked me about my assets, my boat. I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 10 1 am not asking to discuss my assets or my private life 2 with you. 3 Q. What assets did I ask you about? 4 A. A boat. You want to know if I own something and 5 I indulged you, but I am not going to discuss with you 6 what I own, who I live with, what I discussed with my 7 family. 6 I'm here to answer your questions concerning your 9 allegations that I somehow slandered you. That's why, 10 I'm here. I'm happy to answer your questions. 11 MR. O'BOYLE: Counselor, are you instructing 12 him not to answer? 13 MR. GOLDSTEIN: I'm not instructing him at 14 all. 15 MR. O'BOYLE Okay. Would you instruct him to 16 answer, please. 17 MR. GOLDSTEIN: No, I will not instruct him 18 to answer. I don't think you are -- 19 MR. O'BOYLE: I'm sorry. 20 MR. GOLDSTEIN: You have no basis to engage 21 or inquire into his personal life. This is a 22 suit regarding a claim for slander. 23 MR. O'BOYLE: So, you are instructing him 24 not to answer? 25 MR. GOLDSTEIN: I am not instructing him Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 11 1 regardless. I think he answered the question. 2 MR. O'BOYLE: Okay. 3 BY MR. O'BOYLE: 4 Q. Your daughter's a lawyer, correct? 5 A. One of my daughters is a lawyer. 6 Q. Right. Which one would that be? 7 A. Berkley. 8 Q. And her husband is a lawyer, correct? 9 A. Yes, he is. 10 Q. And his name is? 11 A. David Vitale, Junior. 12 Q. And what does Mr. Vitale do? 13 A. What does he do? 14 Q. Yes. 15 A. I don't know what you mean by that. 16 Q. Okay. Has he ever worked for you? 17 A. He has worked for my law firm. 18 Q. Okay. And how long did he work for your law 19 firm? 20 A. I would have to look at records, but I would -- 21 if I were estimating -- I mean, in the range of a year, 22 could have been eight months, it could be 14 months, I'd 23 have to look at the records. 24 Q. That's good enough. And what did he do at your 25 firm? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 12 1 MR. GOLDSTEIN: Object. 2 THE WITNESS: I am not going to discuss his 3 work product at my firm. I am not going to tell 4 you, Mr. O'Boyle, what my personnel do for 5 clients at my firm. I mean, he -- he worked for 6 the firm. 7 MR. GOLDSTEIN: Mr. O'Boyle, again, I said 8 that I would give you some leeway with inquiring 9 as to background information as to 10 Mr. Sweetapple, but starting to delve into 11 employees of the firm and family members of 12 Mr. Sweetapple is completely irrelevant to this 13 case. 14 And I would remind you of the Court's order 15 where it was admonishing all parties, and 16 including your then counsel, that he would not 17 allow for such an inquiry. 18 MR. O'BOYLE: Madam court reporter, can you 19 certify this on the record; Mr. Goldstein, you 20 are completely out of order there. I have no 21 speaking engagements as you are speaking 22 objections, as you know. 23 And you have no knowledge whatsoever about 24 Mr. Sweetapple's son-in-law. As an example, 25 would it be appropriate if he worked on this Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 13 1 file? Would it then be appropriate for me to ask 2 about it? 3 MR. GOLDSTEIN: I am not sure what you mean 4 by "this file"? 5 MR. O'BOYLE: Well, I can show you billing 6 records. 7 MR. GOLDSTEIN: If these -- there's billing 8 records that I have that show that 9 Mr. Sweetapple's son-in-law worked on the present 10 case upon which we are here, I find that hard to 11 believe that you would have such billing records. 12 MR. O'BOYLE: Okay. It wouldn't necessarily 13 have to be on this case, of course. This case is 14 tied into other cases, is it not? 15 MR. GOLDSTEIN: I don't believe this is a 16 separately litigation, so I'm not sure why -- 17 what you mean by "tied into other litigation". 18 MR. O'BOYLE: Well, there's a First 19 Amendment retaliation that Mr. Sweetapple was 20 involved in. 21 MR. GOLDSTEIN: I would disagree with that. 22 And I believe the Court has already dismissed any 23 such claim. 24 So, why don't we move a long, Mr. O'Boyle. 25 MR. O'BOYLE: Okay. Would you be kind Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 enough to show me where the Court has dismissed 2 that claim? 3 MR. GOLDSTEIN: I would be happy to pull up 4 the Court's order granting the Motion to Dismiss. 5 It was entered in this matter with respect to my 6 client. 7 MR. O'BOYLE: And your client being 8 Mr. Sweetapple? 9 MR. GOLDSTEIN: That is correct. 10 MR. O'BOYLE: Okay. So, he's no longer a 11 Defendant, is that correct? 12 MR. GOLDSTEIN: He's no longer a Defendant 13 to any form of retaliation. There's one claim 14 currently pending versus my client and you're 15 fully aware of that what claim is. 16 MR. O'BOYLE: And what you're saying is that 17 I'm restricted from asking him about the First 18 Amendment retaliation claim? 19 MR. GOLDSTEIN: I am not -- 20 MR. O'BOYLE: Is that incorrect? 21 MR. GOLDSTEIN: I am not saying that you're 22 restricted from anything. I'm just advising you 23 of the Court's order regarding discovery in this 24 matter and advising you that, although I'm giving 25 you some leeway, I don't think inquiring as to Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 15 1 what specifics his son-in-law did or where his 2 son-in-law works is relevant to the claims 3 pending in this matter. 4 MR. O'BOYLE: So, are you willing now to 5 show me that order? 6 MR. GOLDSTEIN: If I had a computer here, I 7 would be more than happy to show you that order. 8 I don't have a copy of the order with me. 9 MR. O'BOYLE: Would you call your office and 10 have them fax it here? 11 MR. GOLDSTEIN: I am not going to call my 12 office and have them fax it here. 13 MR. O'BOYLE: So, I'm going to assume that 14 there's no such order. 15 MR. GOLDSTEIN: Assume as you'd like. 16 MR. O'BOYLE: I will. 17 BY MR. O'BOYLE: 18 Q. Your son-in-law, has he worked on any of the Gulf 19 Stream files? 20 A. I am not going to disclose my staff's work 21 product with regard to other cases that are pending in 22 my office. 23 Q. Is he still with your office? 24 A. He does not work with my office now. 25 Q. So, it can't be in connection with work product Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 16 1 in your office, mainly him, specifically, what he's 2 done? 3 A. You mean today? 4 Q. Today, yesterday, last week? 5 A. Well, when he was in my office, the work he has 6 done for my clients on pending cases is work product 7 done for those clients. 8 He has left my office. He works for another 9 firm. I do, occasionally, still call upon him to obtain 10 his legal opinions and to actually perform some work for 11 me, but the majority of the work product that he 12 performed for me was while he was actually employed by 13 the firm. 14 Q. On your billings, where you have billings and 15 explanations associated with David Vitale, are you 16 claiming work product to those? 17 MR. GOLDSTEIN: Object to the form. 18 THE WITNESS: Any work that was done by 19 people in my office on cases for clients, I am -- 20 yes, I'm not going to go into the details of 21 their work product. 22 BY MR. O'BOYLE: 23 Q. On your bills you would have, and I am not 24 reciting how your bills are redacted, I'm just using 25 this by way of example, it will have Vitale's initials Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 17 1 and then it will say worked on brief and the O'Hare 2 matter or whatever matter it is. 3 Is that something that you believe is work 4 product? 5 A. The bills? 6 Q. Yeah. 7 A. Our bills are delivered to the Town and I believe 8 they become a public record. The Town redacts what 9 it -- or the Town's attorneys, I guess, redact as they 10 deem appropriate. 11 But you're asking me for a legal conclusion, if I 12 believe it's work product? I am not here to debate or 13 to discuss what work product is with you. I'm just 14 giving you my understanding with regard to my office. 15 And I do not disclose what my staff or myself do for our 16 clients in working up their cases. And I do not discuss 17 their confidences with other people. 18 Q. If it's on your bill and it recites the name and 19 what he did, are you willing to disclose it and talk 20 about it? 21 MR. GOLDSTEIN: Object. This is asked and 22 answered. 23 THE WITNESS: If you want to show me a bill, 24 I can read the bill just as well as you can. And 25 whatever's on the bill is on the bill. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 IS 1 As far as discussing or testifying as to 2 what lawyers talked about, what cases were 3 researched, what witnesses said when we 4 interviewed witnesses, I would not do that. 5 I don't think suing me for slander is an 6 invitation to take discovery with regard to how 7 we're defending dozens and dozens of cases that 8 are pending, not only against the Town of Gulf 9 Stream but you sued my firm and me. 10 So, I would not -- I would not disclose our 11 work product with regard to those cases or any 12 other clients. 13 BY MR. O'BOYLE: 14 Q. Okay. We'll get back to that. 15 Have you ever seen an airplane banner? 16 A. You mean flying in the sky? 17 Q. Yes. 18 A. Since I was a kid, I've seen airplane banner. 19 Q. When was the last time you have seen one? 20 A. I don't recall. 21 Q. Okay. Have you seen any that you can recall in 22 the last five years? 23 A. Not that I can recall what was said on them. 24 Q. Okay. In general, can you recall what was said 25 and the exact words? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 19 1 MR. GOLDSTEIN: Object to the form. 2 THE WITNESS: I generally recall being at 3 the beach couple years ago and seeing -- I don't 4 know if it was a banner or some type of 5 advertisement in the sky for a Bar or a 6 something, event. I don't know what it was. 7 BY MR. O'BOYLE: 8 Q. Have you ever filed any papers in connection 9 with -- I'm going to put them together, although I'm 10 just doing it for convenience, with regard to any 11 filings in O'Hare or O'Boyle cases, where you wrote 12 about the messages on plane banners? 13 A. Yes. 14 Q. So, you do remember them? 15 A. Remember -- you asked me if I had seen any 16 banners. 17 MR. GOLDSTEIN: Object to form. 18 THE WITNESS: I hadn't seen those banners. 19 BY MR. O'BOYLE: 20 Q. Okay. How did you know about them? 21 A. I am not going to tell you my work product and 22 who described or who provided information, but I did not 23 see those banners. 24 MR. O'BOYLE: And counsel, I'm going to ask 25 you to instruct the witness to answer. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 20 1 MR. GOLDSTEIN: Disclose attorney/client 2 communications? 3 MR. O'BOYLE: That's not an attorney/client 4 communication. He has no knowledge that it's 5 attorney/client privilege. 6 MR. GOLDSTEIN: Nor do you. I'm not going 7 to instruct my client to answer. Ask another 8 question. 9 MR. O'BOYLE: Let's get the Magistrate on 10 the phone. 11 THE COURT REPORTER: Are we taking a recess? 12 MR. O'BOYLE: Yes. 13 (Thereupon, a recess was taken; after which 14 the following proceedings were had:) 15 MR. O'BOYLE: If you would for now, if you 16 would certify that question and answer, I would 17 appreciate it. 18 MR. HOCHMAN: I just want to ask for the 19 record, Mr. O'Boyle, you went off the record to 20 contact the Magistrate Judge. What was the 21 result of that effort? 22 BY MR. O'BOYLE: 23 Q. Mr. Sweetapple, you have been counsel for the 24 Town of Gulf Stream for how long? 25 A. Two years, more than two years. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 21 1 Q. And what were you hired to do? 2 A. I am not comfortable disclosing to you my 3 discussions with the client as to my different roles 4 that I've played as counsel. 5 Q. If I showed you an article in the Coastal Star, 6 and Mr. Morgan confirmed it, would you then be 7 comfortable? 8 A. Comfortable doing what? 9 Q. Explaining what you do at the City, at the Town 10 of Gulf Stream? 11 A. I would never be comfortable discussing with a 12 non -client my communications with a client, and reading 13 a paper would not make me comfortable, I don't believe. 14 Q. Okay. Were you hired to prepare Wills and Truss 15 for the commissioners? 16 A. I am not going to disclose the scope and nature 17 of my communications with a client. I am not 18 comfortable doing that. 19 Q. Were you hired to obscure criminal behavior? 20 A. I am not going to disclose the -- I am not 21 comfortable telling you what I talked about with my 22 client. 23 Q. How much have you billed them so far? 24 A. I actually have no idea. I heard a number 25 Wednesday when I was in here that you used. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 22 1 Q. And? 2 A. I have no idea how much I billed. I've never 3 gone to look and total it. 4 Q. Have you billed a million dollars, do you think? 5 A. I have no idea. 6 Q. But you could have billed a million dollars? 7 A. I could have? 8 MR. GOLDSTEIN: Object to the form. 9 BY MR. O'BOYLE: 10 Q. Yes. Would you have billed or is it out of the 11 question? 12 A. I only billed for work I have done. I have no 13 idea what the total is. 14 Q. Okay. For the work that you've done that you 15 have billed for, could those billings be $1 million or 16 more? 17 MR. GOLDSTEIN: Object to the form. 18 THE WITNESS: I am not comfortable 19 speculating. 20 BY MR. O'BOYLE: 21 Q. Okay. Do you have an accounting system at your 22 office? 23 A. An accounting system. I have an accountant. I 24 don't know what a system is. If he has a system, I'm 25 sure there's some system. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 23 1 Q. And do you ever sit down with your accountant or 2 whoever provides you with financial statements, telling 3 you income, expenses? 4 Have you ever heard of income and expenses? 5 A. Yes. 6 Q. Okay. And if you take the expenses and subtract 7 them from the income, you get the net proceeds or the 8 net income, do you agree with that? 9 A. As a mathematical or accounting principal? 10 Q. As a mathematical or accounting principal, yes? 11 A. And you're asking me if you take net -- would you 12 say that again? I'm not -- if you take net income and 13 deduct net expenses or you take income and you deduct 14 expenses you get net income. 15 Q. That's what I asked. Do you agree with that? 16 A. That's my general understanding of accounting. 17 If you're asking my opinion as to accounting, but I am 18 not an accountant. 19 Q. Okay. Do you ever review financial statements? 20 A. I review financial statements all the time. I do 21 quite a bit of commercial litigation. 22 Q. And do those financial statements reflect the 23 total billings of the firm within a specified period? 24 A. Are you talking now about my financial statements 25 or just financial statements in general? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 24 1 Q. Firm's. 2 A. I am not comfortable disclosing to you my firm's 3 financial information or discussions with accountants 4 which, I believe, are privileged. 5 Q. Aren't the billings to the Town of Gulf Stream 6 public records? 7 A. I think -- I think I already said that. 8 Q. Okay. Then how are they privileged? 9 A. You weren't asking about billings. 10 Q. You said -- But anyway, rather than debate it, 11 you agree that they're not privileged? 12 A. What, sir. 13 Q. The billings that you made to the Town of Gulf 14 Stream? 15 A. The copies of the bills? 16 Q. Doesn't have to be copies, could be originals? 17 A. The originals of the bills you're asking me? 18 Q. I'm asking you the bills. You have copies, you 19 could have originals, you have whatever you want, but 20 you submit bills -- Well, let me back up. 21 Do you submit bills to the Town of Gulf Stream 22 for what you say is your firm's -- your firm's services? 23 MR. GOLDSTEIN: Form. 24 THE WITNESS: My firm sends bills to the 25 Town of Gulf Stream. I'll answer it again, I did Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 25 1 this already earlier. I believe they are 2 reviewed by the Town's council and are redacted 3 as they deem appropriate and then they become a 4 public record. 5 I even believe they're placed somehow on the 6 internet, although I've never seen that, but I -- 7 I understand that. I say, that's my 8 understanding. 9 BY MR. O'BOYLE: 10 Q. How do you know they're reviewed by the Town's 11 council? 12 A. I'm not comfortable discussing with you my 13 communications with the Town's council about those 14 matters. 15 Q. Are you comfortable in discussing with me the 16 legal bills which are public records that you have 17 submitted to the Town? 18 MR. GOLDSTEIN: Asked and answered. 19 THE WITNESS: If you have -- it's not a 20 matter -- if you have a bill that you want me to 21 look at, I'm happy to look at it. I hope it will 22 relate, somehow, to your slander case and that 23 you aren't just intending to take discovery about 24 my work product in other cases. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M. 1 BY MR. O'BOYLE: 2 Q. I have no desire at all to take your work product 3 or to learn anything that is privileged between you and 4 your counsel. 5 I was just -- I would just like to understand, as 6 Plaintiff here and as a member of Gulf Stream, how much 7 money is going out and where is it going. 6 MR. GOLDSTEIN: There's no question pending. 9 THE WITNESS: Yeah. I'm happy to answer 10 your questions. I'm here to answer your 11 questions. 12 BY MR. O'BOYLE: 13 Q. Would you please? 14 A. What's the question. 15 Q. Okay. How much have you billed Gulf Stream 16 for -- would you have accounting records that tell you 17 what you billed Gulf Stream for? 18 MR. GOLDSTEIN: Asked and answered. 19 THE WITNESS: I presume. They can total it, 20 the computer could total it I'm sure. 21 BY MR. O'BOYLE: 22 Q. Have you ever seen it, what you billed? 23 A. No. 24 Q. Never? 25 A. Never looked at it. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 27 1 Q. Okay. How many suits has the Town filed against 2 myself and/or Mr. O'Hare by you? 3 A. Suits that have been filed by the Town against 4 you or Mr. O'Hare? 5 Q. Yes. 6 A. Where you are the Defendants? 7 Q. Yes. 8 A. I believe just the Federal RICO case. 9 Q. Okay. You didn't recently -- I must be mistaken. 10 You didn't recently file a counterclaim? 11 A. You didn't ask me about a counterclaim. 12 Q. I think they're all one, but okay, that's fine. 13 Did you recently file a counterclaim? 14 A. Did I, as an attorney, recently file a 15 counterclaim or did the Town? 16 Q. Did you sign a counterclaim in connection with me 17 and Mr. O'Hare? 18 A. When? 19 Q. In the last six months? 20 A. You'd have to show it to me. I filed a number of 21 counterclaims on behalf of the Town. 22 I know that our firm recently filed a 23 counterclaim against Citizens Awareness Foundation, 24 Inc., and you on behalf of my firm. Mr. O'Hare was not 25 named. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 W 1 So, I'd have to look and see the last 2 counterclaim that named you and Mr. O'Hare. I don't 3 know if it was in the last six months or not. 4 THE COURT REPORTER: I'm sorry, can we take 5 a break so he can finish whatever's he's doing. 6 MR. O'BOYLE: Sure. 7 (Thereupon, a recess was taken; after which 8 the following proceedings were had:) 9 BY MR. O'B0YLE: 10 Q. You mentioned Citizens Awareness just a minute 11 ago? 12 A. I did. 13 Q. What is Citizens Awareness? 14 A. You're asking me my legal opinion? 15 Q. No. I'm asking you in -- to your understanding, 16 what is it? Is it a garage, is it a burger joint? What 17 is it? 18 A. You're asking my legal opinion. 19 Q. No, I'm asking you what it is. If somebody asked 20 me what this piece of equipment in front of me is, I'd 21 say it's a computer. That's not a legal opinion. 22 A. Well, I believe you're asking me a legal opinion. 23 I'm not comfortable giving you my legal opinions. 24 I've been hired to do that for the Town of Gulf 25 Stream. I'll give them my legal opinions as to what Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 29 1 Citizens Awareness Foundation, Inc. is. 2 MR. O'BOYLE: Madam, would you kindly 3 certify the record there. 4 BY MR. O'BOYLE: 5 Q. Do you know a guy named Joel Chandler? 6 A. Do I know him? 7 Q. Yes. 8 A. I wouldn't say I know him. 9 Q. Okay. 10 A. I could say that I've met him and interviewed 11 him. 12 Q. But you don't know him? 13 A. When I say "know him", I mean, that -- to me that 14 means know him, like, socially or personally. I know 15 about him. 16 Q. Tell me about him? 17 A. What do you want to know about him? 18 Q. Whatever you said, I know about him, that's what 19 I want to know? 20 A. Well, I am not comfortable giving you what I know 21 about him from the standpoint that I have had interviews 22 with him that are work product. 23 I have done investigation and research which are 24 work product. And Mr. Chandler is the -- is a witness 25 in numerous cases that are -- or potential witness in Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 numerous cases that are currently pending. 2 Q. Against the Town of Gulf Stream? 3 A. Numerous cases that are pending. 4 Q. Against the Town of Gulf Stream? 5 A. Yes, he's a witness in cases that are pending 6 against the Town of Gulf Stream. He was just listed as 7 a witness in a case that's pending against the Town of 8 Gulf Stream. 9 Q. In your opinion, is he an upstanding, honorable 10 man? 11 A. I am not here to give you my opinions, 12 Mr. O'Boyle. That would be my work product. I am not 13 comfortable doing that. 14 Q. The statement that you took, that's a public 15 record, is it not? 16 A. I'm sorry, which statement are you referring to? 17 Q. How many statements have you taken from 18 Mr. Chandler? 19 MR. GOLDSTEIN: Object to form. 20 THE WITNESS: You didn't identify 21 Mr. Chandler in your question. You just stood 22 up, got up, picked up a piece of paper and asked 23 me the statement that you took. 24 MR. GOLDSTEIN: Bob -- 25 THE WITNESS: So, if you ask me about the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 31 1 statement of Mr. Chandler? 2 BY MR. O'BOYLE: 3 Q. Yes? 4 A. You're asking me for a legal conclusion. But my 5 understanding is, at some point, that became a public 6 record, yes. 7 Q. Okay. So, you have not a problem in the world 8 discussing this? This is not work product? 9 A. I have no problem discussing the fact I took a 10 statement from Mr. Chandler at all. 11 Q. What about the content of the statement, that's 12 public record? 13 A. I'm happy to tell you what I remember him saying 14 and me saying, but I think the transcript is probably 15 the best indication. It was videotaped and transcribed 16 by a court reporter. 17 Q. Let's go through the transcript. 18 A. Do you have a copy for me to look at? 19 Q. I do not, but you won't need one. 20 Incidentally, how did you come about to meeting 21 Mr. Chandler? 22 A. Mr. Chandler called me on the phone. He 23 indicated he wanted to report what he believed was 24 criminal and fraudulent conduct that had been committed 25 by you, your son, a law firm, and an entity by the name Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 32 1 of Cafi, C -A -F -I. 2 Q. And was Mr. Chandler a former member of the FBI, 3 do you know? 4 A. I didn't ask him that question in that 5 conversation. 6 Q. So, you don't know? 7 A. I never -- I have no knowledge of Mr. Chandler 8 being involved with the FBI. 9 Q. Okay. Is Mr. Chandler -- was he involved with 10 the CIA? 11 A. I never asked him that question. 12 Q. So, your knowledge is you don't know? 13 A. I don't know. 14 Q. Okay. Was he ever involved in Interpol? 15 A. I don't know. 16 Q. And is he a lawyer? 17 A. I don't believe so. 18 Q. Okay. And when he spoke to you and he said that 19 I was involved in criminal activities, what were they? 20 A. Are you talking about in the statement that he 21 gave me? 22 Q. Or in the statement or in the affidavit or in the 23 timeline or anything else that he gave us is public 24 knowledge? 25 A. Well, I'll be happy to discuss the statement with Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 33 1 you. I've interviewed Mr. Chandler several times and 2 that's work product. 3 But in that taped interview, there's a discussion 4 of what he believed was potentially criminal and/or 5 fraudulent behavior. I think -- do you want me to tell 6 you what I remember from the statement? 7 Q. Sure. 8 A. I haven't read the statement for some time. But 9 I generally recall there was, in the interview, a 10 discussion that he -- I have to be careful as to what 11 discussions I've had with him that aren't part of the 12 record, so I have to be careful. 13 At some point, he described your funding a 14 purported not-for-profit corporation, but that he was 15 merely only working for you. He was, a long with 16 another man, going around the state making public 17 records requests for purposes of generating, I think he 18 said, you wanted three thousand lawsuits or 25 a day for 19 your son's law firm to file. 20 I don't remember if he mentioned kill shots and 21 triple A kill shots in that transcript or in the 22 communication with me or in the writings he gave me, but 23 there was a -- 24 Q. Excuse me, let me interrupt you and I apologize. 25 MR. GOLDSTEIN: You asked a question, let Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 34 1 him -- 2 MR. O'BOYLE: I understand. 3 MR. GOLDSTEIN: You have to let him finish 4 answering the question. 5 THE WITNESS: Okay. So, then I remember he 6 said that you were funding the entire operation. 7 That you were going to try to get deductions and 8 called it a not-for-profit. 9 That you were -- I am not sure if this is 10 actually in that statement or not, a funded 11 through Commerce Group and otherwise pay for all 12 of the activities to generate these cases 13 throughout the state. 14 That he had gone to numerous state and local 15 governments to make these kill shots to generate 16 lawsuits for your son's law firm that you were 17 funding the firm with an unlimited budget to 18 develop as much legal business as you could for 19 your son in this manner. 20 That you wanted to -- oh, that you had set 21 up your close advisors, I believe it was a 22 Mr. Ring, who was your long term business 23 partner, and Brenda Russell, a secretary, and 24 Denise DeMartini, one of your secretary's, to 25 hold them out as if they were the directors, but Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 35 1 that you were paying him -- that you had actually 2 hired him. 3 That there was never any meetings of Cafi 4 essentially wasn't a real entity, it was just 5 you. That these same people were running the 6 O'Boyle Law Firm with your son. That your son 7 had said he was going to be a lawyer any day, but 8 he was working full-time in the law offices in 9 your same office of Commerce Group. That he was 10 practicing law. That he was running the firm. 11 That he was preparing pleadings. 12 That you had engaged in targeting. You had 13 filed over a hundred public records requests in 14 the name of Cafi, but Cafi was really Commerce 15 Group. Commerce Group was on the forms that you 16 had had your secretary do it and that he was mad 17 about you're saying that you weren't involved 18 with Cafi when you were actually running Cafi. 19 That he didn't want to be part of your 20 targeting. That he -- that lawsuits were filed 21 directed by you on behalf of Cafi when he had 22 been told that he would be in charge of any 23 litigation. 24 That he was instructed to give all the 25 litigation to your son's firm. And that he told Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 36 1 you that he thought that that would clue people 2 into what you were doing, but you insisted. That 3 he had an argument with Mr. Ring about that and 4 Mr. Ring said that, whatever Big Daddy does, he's 5 the money, you have to do what he says. 6 He told me about e-mails and communications 7 involving what he called a "windfall scheme". 8 That not only was the Plaintiff in the cases not 9 a real not-for-profit and a sham that was done to 10 get credibility whenever a suit was filed, but he 11 also told me that he learned through a 12 not-for-profit or some Defendant in a Cafi case 13 that there had been more money demanded by the 14 firm then had been incurred in fees, and that he 15 objected to that and that it had been on-going 16 and it was called the "windfall scheme". 17 And that he had confronted lawyers in the 18 firm, I believe including Jonathan O'Boyle, and 19 he was told that that's the way it's going to be 20 done. 21 And he told me there were e-mails regarding 22 all of that and that you had told him to retract 23 the e-mails or you were going to visit great 24 unpleasantness on him. 25 He told me that Denise DeMartini was running Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 37 1 the law firm with Jonathan, discussing client 2 matters that were not he or Cafi in front of him 3 regularly. That there was what man named 4 Mr. Grey that was being used by the law firm as a 5 runner to go do the same thing. 6 I mean, there's a whole lot of things he 7 told me. It was quite -- quite an earful. 8 BY MR. O'BOYLE: 9 Q. Well, let's go over those things. 10 A. Also, he had provided me, of course, a drop box 11 for -- before I took his statement. 12 Q. And by the way, in that connection, I understand 13 that he wanted to provide to Mr. Richmond the same 14 document that he showed to Mr. Richmond, he refused on 15 basis it was unethical? 16 A. I have no knowledge of discussions between 17 Mr. Chandler and Mr. Richmond regarding the drop box. 18 I do know that I was sued by Cafi and refused to 19 give the drop box to Mr. Richmond or to any -- or to 20 Joann O'Connor because there was a claim made that, I 21 believe, I received a letter from your lawyers, 22 Mr. Ring I believe it was, that I could not -- demanding 23 that back. 24 And I advised Mr. Ring that it was my position, 25 based on what had been related to me, that these were Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 W- 1 allegations of crime or fraud and, therefore, there was 2 no lawyer/client privilege, and that I was going to have 3 the Court decide whether or not these documents had to 4 be returned to this alleged entity called Cafi. 5 And thereafter, I believe, is when you sued my 6 law firm trying to get these documents back and that's 7 been the subject of litigation. 8 Q. I think your first statement was that I was 9 funding Cafi? 10 A. That's not my statement. I'm relating to you 11 what Mr. Chandler told me. He told me you were funding 12 everything, the law firm, Cafi, all of the staff at the 13 companies. 14 That you were, basically -- he used the word Big 15 Daddy, I guess, which is what Mr. Ring called you to 16 Mr. Chandler. And that everything -- whatever you 17 wanted to do is going to be done. And the way you 18 wanted to do it was going to be done. 19 And that Mr. Chandler better just learn that's 20 the way things ran. And Mr. Chandler -- that's what he 21 described to me. 22 I am just telling you, my best recollection of 23 what was in the statement or about that time what he 24 discussed with me. Keeping in mind I had lunch with 25 him. I, also, spoke to him after the statement. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 39 1 So, there are things that may not be on that 2 record. I'm having trouble remembering which is on the 3 record and which was after the record without having the 4 statement in front of me. But you don't want to give me 5 the statement to refresh my recollection, so, I'm giving 6 you my best recollection. 7 Q. Did you pay him off? 8 A. Did I pay him off? 9 Q. Yeah. 10 A. I've never given Mr. Chandler any money for 11 consideration. But I did -- I did buy him a slice of 12 pizza at lunch. And he said, can -- actually, I bought 13 myself a pizza. And he said he wasn't hungry. And he 14 kept looking at my pizza. And he said -- I said, would 15 you like a slice of my pizza? And he said, you sure I 16 can take it? I said, I'm sure you can have slice of my 17 pizza, Mr. Chandler. 18 Q. You had pepperoni? 19 A. I wish my memory were that good. 20 Q. Okay. 21 A. Normally I don't order pepperoni if I'm doing a 22 deposition because I love pepperoni, but it doesn't love 23 me. So, then I stick to mushrooms. 24 If I'm adventurous, I might add onions, but it 25 all depends on what I'm doing that day. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 Q. Gotcha. When you started your long statements a 2 few minutes ago, the first thing you said is that in 3 recalling Mr. Chandler's statement, that he said that I 4 was funding Cafi? 5 A. Are you talking about in the sworn statement? 6 Q. Yes. 7 A. My recollection is that he told me that you were 8 funding everything. 9 Q. Okay. Well, wouldn't Cafi be part of everything? 10 A. Yes, he told me you were funding Cafi and 11 everything. 12 Q. Okay. So, he did say that I was funding Cafi? 13 MR. GOLDSTEIN: Objection. 14 THE WITNESS: That's my recollection. 15 BY MR. O'BOYLE: 16 Q. Tell me what factual evidence that you have that 17 that's true? 18 A. I am not comfortable discussing the contents of 19 the drop box that was provided to me because the same 20 lawyer you were using in this case, Mr. DeSusa, is, 21 apparently, also representing Cafi. And he filed suit 22 against my law firm claiming that these are confidential 23 materials of Cafi. 24 So, until a court adjudicates case that or until 25 they are released in some other fashion, I am not Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 41 1 comfortable answering that question. 2 Q. And I am not asking for one document. 3 A. And I don't want to talk to you about what's in 4 the documents. 5 Q. And I'm not asking for you to talk to me about 6 what's in the document. 7 A. Okay. 8 Q. What I'm asking you is, am I correct in that 9 Mr. Chandler said that I was funding Cafi? 10 MR. GOLDSTEIN: Asked and answered. 11 BY MR. O'BOYLE: 12 Q. And you said yes, correct? 13 A. The record speaks for itself, Mr. O'Boyle. You 14 asked me that question three or four times. 15 MR. GOLDSTEIN: Asked and answered. 16 BY MR. O'BOYLE: 17 Q. Okay. Your exaggeration aside -- 18 A. I'm sorry? 19 Q. I said, your exaggeration aside -- 20 A. Is that a question? 21 MR. GOLDSTEIN: There's no question pending. 22 MR. O'BOYLE: I'm going to continue on and 23 get a question. 24 THE WITNESS: And I'm going to need a 25 restroom break shortly. It's been an Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 42 1 hour-and--a-half I've been here. 2 BY MR. O'BOYLE: 3 Q. In this sworn statement dated -- 4 A. Do you mind if we take a restroom break if you're 5 going to go through the entire statement? 6 Q. Not at all. 7 A. It's just a two -minute break. 8 MR. HOCHMAN: We're off the record. 9 MR. O'BOYLE: Takes two to go off the 10 record, but we'll go off the record. 11 MR. HOCHMAN: Exactly gotcha. 12 (Thereupon, a recess was taken; after which 13 the following proceedings were had:) 14 MR. O'BOYLE: Would you like to go back on 15 the record? 16 MR. HOCHMAN: Yes, certainly. 17 BY MR. O'BOYLE: 18 Q. On July 23, 2014 between 10:48 a.m. and 19 3:56 p.m., and the time is insignificant just trying to 20 do it to, maybe, help you out. Did you take a sworn 21 statement from Joel Chandler? 22 MR. GOLDSTEIN: Asked and answered. 23 THE WITNESS: Yes. Except for the lunch 24 recess. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 43 1 BY MR. O'BOYLE: 2 Q. Okay. 3 A. And yes, that's -- 4 Q. Just one quick question, did you tell me about 5 the last -- about the lunch recess when we -- the last 6 time when Mr. Goldstein said it was asked and answered? 7 A. Yes, I told you about the pizza. 8 Q. You did? 9 A. And that was related to the sworn statement when 10 I was having sworn statement. The court reporter wasn't 11 there. So, other than that time period, I was taking 12 the sworn statement. 13 Q. Okay. You did take this sworn statement? In 14 other words, there's questions and answers in here from 15 Mr. Sweetapple and Mr. Chandler? 16 A. I think you asked me that. Yes. 17 Q. Okay. And in that sworn statement it talks about 18 Joel Chandler saying that I was funding Cafi. 19 Do you claim that a public statement in this 20 public document to be work product or privileged? 21 MR. GOLDSTEIN: Object to the form. 22 THE WITNESS: I'm not going to give you my 23 legal conclusion, but I have recited -- I mean, I 24 am admitting that I asked that question and he 25 gave that answer and it's part of a public Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 record. 2 BY MR. O'BOYLE: 3 Q. And do you have any reason to believe that that's 4 true, that statement? 5 A. I'm not going to disclose my work product. I am 6 not comfortable discussing my work product to you or my 7 opinions, my legal opinions. 8 Q. I don't want your legal opinions. 9 Tell me how that's work product? Help me out? 10 A. I'm not going to help you out, sir. You had an 11 attorney and you've chosen to proceed without an 12 attorney. 13 Your son's an attorney. You can ask him during a 14 break. 15 MR. O'BOYLE: Would you certify the 16 question, please. 17 BY MR. O'BOYLE: 18 Q. We'll get to that when we go through the 19 document. 20 What's a kill shot? 21 A. That is a term that Mr. Chandler used in his 22 discussions with me. 23 Q. How did you -- he's not a hired killer or 24 anything like that to your knowledge, is he? 25 A. No. You want my understanding -- what, basically, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 he was describing to me was the making of public records 2 requests with no intent to get the documents, but to 3 have it so difficult or orchestrated in a way that it 4 would not be answered in such a way that the lawsuit 5 that would come from it would result in an obligation on 6 behalf of the government entity to have to pay fees so 7 there would be, as he explained it, no way they would 8 know there was a record that existed, they forgot to 9 include, so complex. 10 But basically, it was the way to go around and to 11 farm lawsuits. And I believe there's an e-mail that's 12 not -- that's before Cafi was formed that's not part of 13 the claim Cafi confidential documents, that talks about 14 the kill shot. And how many he -- I may -- I may have 15 that. 16 I brought a stack of documents with me. If 17 during the break I could look. But I think there's an 18 e-mail that actually talks about the kill shots that was 19 prior to Cafi being formed. 20 Q. And if it was prior to Cafi being formed, who 21 would it involve? 22 A. It involved Mr. Whitmore, your son's law firm, a 23 discussion of how many cases could possibly be farmed 24 using these kill shots for the law firm. 25 Q. And this is all from Mr. Chandler, am I correct? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 E 1 A. No. There's e-mails between Mr. Whitmore and 2 Mr. Chandler before Cafi was formed when the law firm 3 was being setup to handle this type of activity. 4 Q. And when you say "this type of activity", you're 5 talking about Mr. Chandler preparing complaints for 6 Mr. Whitmore, is that what you're saying? 7 A. No. I'm talking about the business model that was 8 being setup, whereby, Mr. Chandler, Mr. Grey would go 9 around the state and with no desire to get public 10 records, saying they were representing -- just not 11 saying they represent Cafi, just going out there and 12 asking for records. 13 You were paying them or paying Mr. Chandler, that 14 he had your credit card, I believe he said. You gave 15 him $1,000. And then these were kill shots where the 16 really good ones that he thought were great lawsuit he 17 would bring to the law firm. You would call it a Cafi 18 public records request. Some of these were oral. He 19 would just go in and make requests and then he would 20 come back, the law firm would file lawsuits saying it 21 was Cafi, which is a not-for-profit so that the 22 recipient would believe it's a legitimate entity that's 23 making these requests. 24 And the kill shot was part of the mechanism that 25 he described. And I believe it's in an e-mail that I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 47 1 could get for you. 2 Q. The documents that Mr. Richmond didn't want or 3 Joel didn't want to give them to him, I am not sure I 4 grasp what you were saying in full. 5 But Mr. Chandler gave to you confidential 6 documents, did he not? 7 MR. GOLDSTEIN: Object the to form. 8 THE WITNESS: Mr. Chandler sent a drop box 9 to me after we had a discussion on the telephone. 10 BY MR. O'BOYLE: 11 Q. And Mr. Chandler was no longer with Cafi at that 12 point, am I correct? 13 A. I don't -- I don't believe he was from the 14 conversation. 15 Q. So, if he wasn't with Cafi and he had Cafi 16 documents where there communications with lawyers and so 17 forth, wouldn't they be privileged? 18 A. You're asking me for -- first of all, there's 19 hypotheticals in the question. And second of all, 20 you're asking me for a legal opinion. 21 Q. Okay. Do you believe -- I believe that those 22 documents were stolen, that's what I believe. 23 And if I'm correct, isn't that kind of activity a 24 felony? 25 A. I am not here to give you my legal opinion with Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 WM 1 regard to your legal matters. 2 MR. GOLDSTEIN: Going to object to the form. 3 BY MR. O'BOYLE: 4 Q. Okay. 5 A. And I don't understand -- 6 MR. GOLDSTEIN: There's no question pending. 7 THE WITNESS: That's all. I am not here to 8 give you a legal opinion. 9 BY MR. O'BOYLE: 10 Q. And I wouldn't want a legal opinion from you. 11 Thank you. 12 MR. GOLDSTEIN: Move to strike the 13 commentary. 14 BY MR. O'BOYLE: 15 Q. Where did Joel get these documents, he didn't 16 work for Cafi, they were Cafi documents. Where would he 17 have gotten them, do you have any idea? 18 MR. GOLDSTEIN: Object to the form. 19 THE WITNESS: Mr. Chandler told me they were 20 his documents. 21 BY MR. O'BOYLE: 22 Q. You're a lawyer, you know better, don't you? 23 MR. GOLDSTEIN: There's no question pending. 24 Object to the form. 25 THE WITNESS: Are you saying that I should Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 have doubted Mr. Chandler? 2 BY MR. O'BOYLE: 3 Q. No. I think you should have looked at the 4 documents. You knew that Mr. Chandler was no longer 5 with Cafi. You knew that the documents were between 6 Cafi and their counsel, and you took them anyway. 7 MR. GOLDSTEIN: Object to the form. 8 THE WITNESS: There were a number of 9 different types of documents in the drop box 10 before I allowed -- at the very onset of my 11 discussion with Mr. Chandler, I instructed him 12 that I did not want to talk to him unless he had 13 an independent attorney. 14 He indicated to me that he had spoken to, in 15 excess of, ten attorneys about what was 16 happening. He indicated to me that he had 17 already contacted numerous victims. That I was 18 hardly the first person he was contacting. 19 And I indicated to him that I would be more 20 comfortable if he had an attorney. And he said 21 he didn't need one. And I said, fine. I am 22 happy to proceed. 23 And he sent me a drop box. And I told you 24 what my position was with regard to that drop box 25 when your -- when Mr. Ring made a demand for Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 50 1 those documents back and it's the subject of 2 on-going litigation. 3 BY MR. O'BOYLE: 4 Q. When you got the drop box and the documents, did 5 you look at the documents? 6 A. They were so voluminous that I did not look at 7 them. I looked at some of them. I am not very savvy 8 with the computer, it was on a computer. 9 I didn't know what a drop box was at the time. I 10 looked at some of it. And I, actually, said to 11 Mr. Chandler, because I'd arranged to go immediately to 12 see him, could you please write out a chronology for me 13 so that I know what you're talking about. 14 And then he sent me another computer document 15 which was a chronology with like e-mails. So, I did 16 look at that. 17 Q. But of the e-mails that you looked at, were any 18 of them between Cafi and counsel? 19 MR. GOLDSTEIN: Object to the form. 20 THE WITNESS: I'd have to go back and look. 21 BY MR. O'BOYLE: 22 Q. You don't remember? 23 A. I don't. I don't. I really don't feel 24 comfortable talking about those documents anyway as to 25 what they said. I haven't looked at them in a long, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 51 1 long time. 2 But I do -- I do believe there were e-mails 3 between Jonathan and Joel. Whether or not that's Cafi 4 or not, of course, is a legal conclusion. 5 Q. Hm-hum. The documents in the drop box, in either 6 the to or from, did you see the name Cafi or Citizens 7 Awareness Foundations, Inc.? I am not sure how it shows 8 up. 9 A. I don't remember that. I remember Joel Chandler 10 and different people. 11 Q. Okay. So, you don't remember of all those 12 documents in the drop box? You don't remember one that 13 said Cafi? 14 A. Well, I am not -- that's not what I said. I said 15 I don't remember if, in the e-mails, where it said from 16 Joel to Whitmore, to -- or Ring to Joel, if it said Cafi 17 or just Joel. 18 Mr. Chandler's position was that he -- that the 19 employment by Cafi was just a ruse. 20 Q. And my position is, is that he's a pedophile. 21 A. Is that a question? 22 Q. No. You were just telling me what his position 23 is. 24 A. I'm just telling you what he told me. I don't 25 know what your dealings with him are or how you would Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 52 1 believe he's a pedophile. 2 MR. HOCHMAN: Can you read back the 3 statement on the record where Mr. O'Boyle made a 4 comment about Mr. Chandler? 5 MR. O'B0YLE: Please, strike that, please. 6 MR. HOCHMAN: I just want it read back so I 7 can hear exactly what the -- so I can write it 8 down in my notes. 9 MR. O'BOYLE: Would you, please, strike 10 that. He can write down all he wants. 11 (Thereupon, the last pending question was 12 read back; after which the following proceedings 13 were had:) 14 MR. HOCHMAN: Do you know what page that's 15 on in terms of where you are, approximately? 16 THE COURT REPORTER: About 47 to 50. 17 MR. HOCHMAN: I would like an excerpt, 18 please, of the couple questions before that and 19 to the point that I'm saying this is now excerpt 20 number one. Thank you. 21 So, I may not order the entire transcript, 22 but I'm going to ask for the excerpt. Thank you. 23 MR. O'B0YLE: Is your speech over? 24 MR. HOCHMAN: I was making a request to the 25 court reporter so I can an order a portion of the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 53 1 transcript. 2 MR. O'BOYLE: You could have done that 3 later. 4 Are we back on the record? 5 THE COURT REPORTER: We were always on. 6 MR. O'BOYLE: And, again, I just want to say 7 that to my knowledge, Mr. Chandler is not a 8 pedophile and I would never accuse him of being a 9 pedophile. 10 Moving a long. 11 BY MR. O'BOYLE: 12 Q. Did Mr. Chandler, when he sent you the drop box, 13 you read certain documents you said? 14 A. I did look at certain documents. 15 Q. Okay. How many documents were in the drop box, 16 approximately? 17 A. I don't know. 18 Q. Was there less than a million? 19 A. I'm certain. 20 Q. Excuse me? 21 A. I'm certain. 22 Q. Okay. Was there less than a hundred thousand? 23 A. I'm certain. 24 Q. Okay. Was there less than fifty thousand? 25 A. I believe so. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 54 1 Q. Okay. Was there less than twenty-five thousand? 2 A. I never counted them. I would think there's less 3 than twenty-five thousand. 4 Q. Is there less than ten thousand? 5 A. I'd have to see it printed out and look at them. 6 I mean, if I were guessing, I would say -- 7 MR. GOLDSTEIN: Don't guess. 8 THE WITNESS: I mean, I really would 9 have to -- I'm guessing. 10 MR. GOLDSTEIN: Let me move to strike any 11 questions characterized as a guess. 12 THE WITNESS: Okay. I would be guessing. 13 I never counted the number of documents. 14 BY MR. O'BOYLE: 15 Q. So, it could be twenty thousand and it could be 16 nine, correct, somewhere between there? 17 A. It was more -- I think when they printed it, it 18 was more a notebook, it wasn't a box. 19 Q. And when you say "notebook", one of the big black 20 books? 21 A. It's a black book. I don't know, you know, how 22 big or how many pages there are. 23 Q. Okay. 24 A. I had it printed because I don't often read 25 documents on the computer. I'm old fashioned, 36 years Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 55 1 of doing this. I'm learning, though. 2 Q. And I appreciate that. Although, a few minutes 3 ago you just said the very opposite and that is, that 4 you were looking at them on the screen? 5 A. I tried that, but I'm not comfortable doing that 6 because I like to underline and I like to -- so, I'll do 7 that, I'll glance at things on the screen. 8 But I always have them print it out. I'm a tree 9 killer from way back. 10 Q. Okay. 11 A. Although, I'm trying to get around that. 12 Q. Okay. Good enough with me. 13 So, I guess just as a follow up question, you 14 don't think that anything in connection with your 15 conduct, Joel Chandler's conduct in connection with the 16 drop box, the Cafi documents, you don't think there's 17 anything wrong with what you've done morally, ethically, 18 legally, nothing? 19 MR. GOLDSTEIN: Object to the form. 20 THE WITNESS: You're asking me for my legal 21 opinion. I can tell you that all times as a 22 lawyer, I try to conduct myself in a way that's 23 ethical, legal and even moral. 24 So, no, I don't believe that anything that I 25 did in receiving this person's attempt to inform Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 56 1 me on behalf of the Town of Gulf Stream of what 2 he believed was criminal and fraudulent conduct 3 directed, not only to Gulf Stream but to over a 4 hundred governments in the state, was immoral, 5 unethical or illegal. 6 I believe I had a duty to receive that 7 information on behalf of my client. 8 BY MR. O'BOYLE: 9 Q. Do you believe you had a duty to submit that to 10 the Bar? 11 A. Had my client not filed a Bar complaint, I think 12 the ethical rules required that when a lawyer becomes 13 aware of unethical conduct or alleged unethical conduct 14 with regard to another lawyer, we do have a duty to 15 report that to the Bar, yes. That's my understanding of 16 the Bar rules. 17 Q. So, if what you did in connection with the drop 18 box in reading the documents and so forth is immoral, 19 unethical or illegal, one of the lawyers here, probably 20 Mr. Goldstein, would report you to the Bar and that 21 would be appropriate, am I correct? 22 A. You're asking me my legal opinion? 23 Q. No. 24 A. I'm telling you that my -- you're asking me my 25 general understanding. I'll give it to you from my Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 57 1 experience; is that if a lawyer becomes aware of a 2 breach of the rules regulating the Florida Bar by 3 another lawyer, he has a duty to report that. 4 Q. Okay. The amended counterclaim that was filed in 5 Case 4474, do you know anything about that? 6 MR. GOLDSTEIN: Object to the form. 7 THE WITNESS: I believe that is a public 8 records case that you filed against the Town of 9 Gulf Stream. 10 BY MR. O'BOYLE: 11 Q. The amended counterclaim is what you think I 12 filed? 13 A. No, no, that Case 44 -- 14 Q. That's not what I asked you. 15 A. Do I know anything about the counterclaim? 16 Q. Yeah, the amended counterclaim? 17 A. I know that there was an amended counterclaim 18 filed in that case. 19 Q. Do you have any idea who filed it? 20 A. I believe my firm filed it with O'Connor, 21 Joann O'Connor's firm. 22 Q. Okay. So, it would have been signed by you and 23 Joann O'Connor, is that what you're saying? 24 A. I would have to see the document. I mean, it 25 doesn't have to be signed by both attorneys of record. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 Q. But it was signed by you? When I say "you", I 2 mean your firm. 3 MR. GOLDSTEIN: Asked and answered. 4 THE WITNESS: I would have to see the 5 document, but I don't know. If it was 6 electronically filed, I don't know if I signed 7 it. If you show it to me, we'll know. 8 BY MR. O'BOYLE: 9 Q. Ah -huh. Okay. Are you familiar with the Bar of 10 the Rules? 11 A. Generally, yes. 12 Q. Sorry? 13 A. Yes, I am generally familiar with the Bar rules. 14 Q. And what's the difference between being familiar 15 with the Bar rules and generally being familiar with the 16 Bar rules? 17 MR. GOLDSTEIN: Object to the form. 18 THE WITNESS: When I served as vice chair of 19 the Florida Bar Grievance Committee along with 20 Judge French, I was very familiar with the Bar 21 rules because I worked with them on a weekly 22 basis. 23 Now, if you ask me a specific question about 24 a specific number or content, I would have to 25 look at the rules to recite them to you. But Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 59 1 there was a time when that wasn't necessary. 2 BY MR. O'BOYLE: 3 Q. The sworn statement that you took from 4 Mr. Chandler, are you relying on it? 5 A. What do you mean, am I relying on it? 6 MR. GOLDSTEIN: Object to form. 7 BY MR. O'BOYLE: 8 Q. Okay. I have to type a letter and I'm relying on 9 this computer to not break down and allow me to type the 10 letter. 11 Are you relying on the content of this document 12 which you took from Mr. Chandler? 13 MR. GOLDSTEIN: Object to the form. 14 THE WITNESS: For what purpose? 15 BY MR. O'BOYLE: 16 Q. The truth? 17 A. I had Mr. Chandler swear to anything he told me. 18 Q. And what happens if you have conflicting 19 information? 20 If Mr. Hochman says white and Mr. Goldstein says 21 black or Mr. Chandler says red, Marty O'Boyle says 22 green, how do you handle that? 23 A. How do I handle that? 24 Q. I asked you first. 25 A. I'm not a judge. I am not a jury. I don't Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 z 1 adjudicate people's credibility. I interview witnesses. 2 I only file things that I think are in good faith. 3 If I thought someone was lying to me, I certainly 4 would not use their statement, but I don't -- I don't 5 know how to answer your question other than that. 6 Q. Well, about the veracity of the document, the 7 statement's made. Are you -- probably not using the 8 right word, please excuse me, but are you relying on -- 9 for all of your -- not for all, but for many of your 10 future pleadings, filings from this, are you relying on 11 the content of this? 12 MR. GOLDSTEIN: Object to the form. 13 THE WITNESS: I am not capable of telling 14 you what my future pleadings are going to be. 15 BY MR. O'BOYLE: matters, legal matters, 16 Q. No, no. 17 A. Nor am I comfortable telling you my work product 18 and what statements of what witnesses I'll be relying on 19 for my representation of the Town and various matters 20 that are filed or un -filed for that matter. 21 Q. Have you not filed pleadings since the date that 22 you took this? When I say "pleadings", may not be the 23 right term. 24 You have filed documents -- you filed -- you made 25 filings in connection with court matters, legal matters, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 61 1 litigations, am I correct? 2 MR. GOLDSTEIN: Object to form. 3 THE WITNESS: On behalf of the Town of Gulf 4 Stream? 5 BY MR. O'BOYLE: 6 Q. On behalf of the Town of Gulf Stream? 7 A. I made many, many filings on behalf of the Town 8 of Gulf Stream. 9 Q. Okay. And I'm going to tell you that many of 10 your filings that I've seen include much of what is in 11 here. Does that sound correct to you? 12 MR. GOLDSTEIN: Object to form. 13 THE WITNESS: That you said most of my 14 filings? 15 BY MR. O'BOYLE: 16 Q. Yes, most. 17 A. I would have to look at all the filings. I'd 18 have to look at all the filings and weigh them and count 19 them to see if there's a reference to any of that 20 testimony. 21 Q. Well, let's take baby steps. Let's take one 22 filing. Have you in any one filing used information 23 that's in this sworn statement you took from 24 Joel Chandler? 25 A. Yes. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 z 1 Q. Okay. And what documents do you remember with 2 specificity? 3 MR. GOLDSTEIN: Object to the form. 4 THE WITNESS: Where I actually filed that or 5 where I actually made a reference to it? 6 BY MR. O'BOYLE: 7 Q. Have you found -- 8 A. There's a long statement and he also provided an 9 affidavit. 10 Q. Right. 11 A. And I -- I -- 12 Q. I am not talking about either, by the way. 13 A. Okay. Please, restate your question. I am not 14 sure exactly what you want because I want to get the 15 right answer. 16 Q. Sure. Thank you. You have filed, after July 23, 17 2014, pleadings, filings, whatever they're called in 18 connection with certain cases which would be the Town of 19 Gulf Stream versus my son, myself, Mr. O'Hare, would 20 that be correct? 21 MR. GOLDSTEIN: I'm going to object to the 22 form of the question. 23 THE WITNESS: What was the question again? 24 BY MR. O'BOYLE: 25 Q. I'm talking about cases, whether they be counter Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 63 1 claims, whether they be motions, whether they be 2 straightforward claims. 3 I told you I'm not adjoined when it comes to the 4 names of the -- of the documentation, but your filings? 5 A. What about my filings again? 6 MR. GOLDSTEIN: Mr. O'Boyle, do you have a 7 specific filing that you're referring to that you 8 can direct him. I think it would be easier. 9 BY MR. O'BOYLE: 10 Q. Okay. Well, thank you. Lunch time, if you would 11 like -- you can buy me lunch and I would appreciate it. 12 You filed a counterclaim in 4474, do you remember 13 what was in that counterclaim? 14 MR. GOLDSTEIN: Object to the form. 15 THE WITNESS: I prefer to see the original 16 counterclaim to answer. But I remember a 17 declaratory judgment count, I believe. 18 I believe I was -- I'd have to see the 19 original pleading. I know, at some point, I was 20 trying on behalf of Gulf Stream to have the court 21 rule on the issue of the Cafi documents, 22 something like that. I'd have to see the 23 pleading to be safe. 24 BY MR. O'BOYLE: 25 Q. Okay. Besides 4474 -- let's move for a little Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 bit. 2 Do you remember preparing a document and at my 3 deposition you threw it on the table and said, did you 4 say this is the biggest piece of shit you'd ever seen, 5 do you remember that? 6 A. Did I -- I'm sorry, did I see a document? 7 Q. No, that's not what I said. Listen closely. 8 A. Okay. 9 Q. I said, do you remember at my deposition that you 10 took, do you remember pulling out a document and 11 saying -- putting it on the table and saying, did you 12 say that this was the biggest piece of shit you'd ever 13 seen? 14 A. Ask you that question? 15 Q. Yes. 16 A. In -- 17 Q. Yes. 18 A. I'd have to see that question in the transcript. 19 Q. You don't deny it, though? 20 A. I'd have to see it. 21 Q. But you don't deny that you said it? 22 A. I am not admitting or denying it. I need to -- 23 if there's a transcript it will say what I said. 24 I don't -- unless you used that word, I try not 25 to cuss in legal proceedings. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 65 1 Q. You said, the biggest piece of shit that I'd ever 2 seen. 3 A. I think -- 4 Q. And what that was was about an UPL against my 5 son. 6 A. That you had said that -- I've heard you say this 7 is the biggest piece of shit I'd ever seen about a 8 motion to disqualify the O'Boyle Law Firm. 9 Q. Okay. 10 A. I remember something about that when you said 11 that. I don't think it was the Joel Chandler statement. 12 I think that was a motion that I had filed a long which 13 Joann O'Connor on behalf of the Town to disqualify the 14 O'Boyle Law Firm. But that was before -- that was 15 before I took a statement from Mr. Chandler. 16 Q. I don't think you're correct, but I can't say 17 that you're wrong? 18 Q. I don't think you're correct. 19 MR. GOLDSTEIN: Move to strike. 20 THE WITNESS: In fact, I'm certain of it. 21 MR. GOLDSTEIN: There's no question pending. 22 BY MR. O'BOYLE: 23 Q. What was your a factual basis for saying that my 24 son was guilty of the unlicensed practice of law? 25 When I say "your factual basis", we're going to Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 exclude from that any non -facts that you have. 2 MR. GOLDSTEIN: Okay. Mr. O'Boyle, again, I 3 I'm going to object. If you can tell me how this 4 is relevant to the claims of -- that my client 5 allegedly slandered you, I would be happy to 6 listen to -- or for you to advise me. 7 MR. O'BOYLE: If you want to instruct him 8 not to answer, you're more than welcome to do 9 that. 10 MR. GOLDSTEIN: I am not instructing him 11 either way. I just want asking for you to 12 advise how a -- 13 MR. O'BOYLE: Kindly -- 14 MR. GOLDSTEIN: -- motion that's filed -- 15 MR. O'BOYLE: -- ask him to kindly answer 16 the question, please. 17 MR. GOLDSTEIN: I'm asking as to how a 18 motion that was filed completely separate from 19 the litigation has any relevance to the claim -- 20 MR. O'BOYLE: I am not going to answer you. 21 MR. GOLDSTEIN: -- or to him. 22 THE WITNESS: If you want to talk about the 23 facts -- 24 MR. O'BOYLE: Yes. 25 THE WITNESS: -- that will support the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 67 1 Town's position that there was unlicensed 2 practice of law by the O'Boyle Law Firm, that was 3 set forth in a motion that was filed with the 4 court. And the facts, I believe, are set forth 5 in that motion. 6 If you handed me a copy of the motion, I 7 could recite for you all of the facts. If you 8 want me to generally recall the facts, I can do 9 that. If you want me to give you the facts that 10 were provided by Mr. Chandler after the motion 11 was filed, I am happy to try to do that for you 12 as well. 13 BY MR. O'BOYLE: 14 Q. I appreciate that and thank you. 15 What I would be interested in is, as they say in 16 Dragnet, just the facts please? 17 A. Okay. You want the facts that are in the Motion 18 to Disqualify. 19 Q. No, sir, I want the facts. 20 MR. GOLDSTEIN: Object to the form. 21 THE WITNESS: Any fact that went to the 22 unlicensed practice of law that was put out? 23 BY MR. O'BOYLE: 24 Q. Yes, any fact. And let me see if I can clarify 25 what I'm thinking. Fact, the court reporter is sitting Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 about eight -foot from me. 2 Not a fact, on the other side of the building 3 there's another court reporter who's there. I think she 4 is, but I can't say for sure. I have no factual basis 5 to make such a statement. 6 I have a factual basis to say that she's here. 7 That's a -- 8 A. The facts that I am aware of that have been set 9 forth in pleadings, statements, filings -- 10 Q. Just facts. 11 A. That I am aware of, the just facts -- 12 MR. GOLDSTEIN: Do you want to ask him a 13 question? 14 THE WITNESS: The facts that I am aware 15 of -- 16 MR. O'BOYLE: I asked him a question. 17 MR. GOLDSTEIN: Then stop interrupting him. 18 MR. O'BOYLE: Sure. Stop interrupting me. 19 THE WITNESS: The facts that I'm aware of that 20 have been made public in filings or statements 21 that I remember now sitting here include a 22 confrontation between Judge Barkdull and Jonathan 23 O'Boyle where that issue was raised. 24 BY MR. O'BOYLE: 25 Q. Okay, let's stop. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 A. Well, let me finish my answer, please. 2 MR. O'BOYLE: Let's stop. 3 MR. GOLDSTEIN: You've asked him a question, 4 let him answer. 5 MR. O'BOYLE: I'll withdrawing my question. 6 We'll ask them one a the a time. 7 THE WITNESS: You've only given one. 8 MR. O'BOYLE: That's all I need for now. 9 BY MR. O'BOYLE: 10 Q. You said one of the facts is, that confrontation 11 between Judge Barkdull and Jonathan O'Boyle. Tell me 12 how that constitutes the unlicensed practice of law, 13 please? 14 MR. GOLDSTEIN: Object to the form of the 15 question. 16 THE WITNESS: I was giving you a preface to 17 my answer to say that I retrieved a transcript of 18 a -- this colloquy between the Judge and Jonathan 19 where he said, we're about to discuss the 20 unlicensed practice of law and asked him to move 21 back from the bar, which was one of the first 22 times I think I realized that Jonathan was not a 23 member of the Florida Bar. 24 And there is record evidence, public record 25 evidence, that the O'Boyle Law Firm in Florida Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 70 1 registered itself purporting to be a branch, 2 let's say, let's simplify it, a branch of the 3 O'Boyle Law Firm that was in Philadelphia. 4 And the evidence that was presented in the 5 filings was that Mr. Jonathan O'Boyle was living 6 full-time in Florida. That he told the 7 Pennsylvania Bar that he was not active in 8 Pennsylvania, and that he actually resided at a 9 residence address in Gulf Stream. 10 So, that the parent corporation that was 11 supposed to be sponsoring the branch office of 12 the O'Boyle Law Firm had no lawyer in it. It was 13 supposed to be Jonathan, but he resided in Gulf 14 Stream and was not an active member of the 15 Pennsylvania Bar. 16 In addition, facts were asserted by 17 Mr. Chandler that Jonathan was -- 18 BY MR. O'B0YLE: 19 Q. Excuse me. Mr. Chandler is not -- you cannot use 20 Mr. Chandler for factual information. There's no 21 factual information. I want to know facts? 22 A. Well, a statement of a witness -- 23 Q. Aside from -- 24 MR. GOLDSTEIN: Okay, don't -- 25 MR. O'BOYLE: That's fine. And once again I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 71 1 apologize for not being clear. 2 MR. GOLDSTEIN: I think you also don't need 3 to interrupt Mr. Sweetapple's answer. 4 MR. O'BOYLE: I don't want you to keep 5 interrupting me. 6 MR. GOLDSTEIN: Well, I respect that you 7 give him the same respect that you're demanding. 8 MR. O'BOYLE: I respect that you give me the 9 same respect. 10 MR. GOLDSTEIN: I will when you do so to my 11 client. 12 MR. O'BOYLE: So, you're not going to give 13 me respect is that what you're saying, counsel? 14 MR. GOLDSTEIN: No. I'll give you the 15 respect and I expect it to be reciprocated. 16 MR. O'BOYLE: It's only conditional is that 17 what you're saying, counsel? 18 MR. GOLDSTEIN: I'm not saying it's 19 conditional. I'm expecting you to reciprocate and 20 allow the witness to finish answering the 21 question. 22 THE WITNESS: Could we take a break while 23 you're -- 24 MR. HOCHMAN: Can I ask you to read back the 25 record what Mr. O'Boyle said about what Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 72 1 Mr. Chandler says is not a fact. I just want to 2 write that down for my notes, please. 3 MR. O'BOYLE: No, that's not a fact. 4 THE COURT REPORTER: We're off the record. 5 (Thereupon, a recess was taken; after which 6 the following proceedings were had:) 7 BY MR. O'BOYLE: 8 Q. Mr. Sweetapple, we just completed a break. And 9 as in any hiatus, you sometimes lose your place and I 10 may have. I don't know that I did, but I may have. 11 We were talking about facts for the UPL and you 12 mentioned Judge Barkdull and then I think you were, for 13 lack of a better way of saying it, moon walking. What 14 does Judge Barkdull have to do with facts -- 15 MR. GOLDSTEIN: Object to form. 16 BY MR. O'BOYLE: 17 Q. -- regarding Jonathan O'Boyle and your claim that 18 he was engaged in the unauthorized practice of law? 19 MR. GOLDSTEIN: Asked and answered. 20 THE WITNESS: I'm trying to answer your 21 question as best as I can. Do you want to tell 22 me what your pending question is? I heard moon 23 walking. 24 BY MR. O'BOYLE: 25 Q. Yeah, I just did. Would you like me to repeat it Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 again? 73 2 A. If you could. 3 Q. I would be delighted to. 4 I asked you for, in connection with the UPL that 5 you filed against Jonathan O'Boyle, the document that I 6 said, this is the biggest piece of shit that I'd ever 7 seen. 8 In connection with that document, what factual 9 information was in that document that would make 10 Jonathan guilty of the unauthorized practice of law? 11 MR. GOLDSTEIN: Object to the form. 12 THE WITNESS: That document has facts 13 alleged in it. First of all, it was a motion to 14 disqualify a law firm. I don't believe it sought 15 to find Jonathan guilty of the unlicensed 16 practice of law. It was not any type of a 17 charging document. 18 And I told you that one of the things I 19 recall being in the motion were facts regarding 20 the presence of Jonathan practicing law in 21 Florida, allegedly, on behalf of a branch office 22 and there was no main office that had a lawyer 23 because the main office was supposed to be 24 Jonathan in Pennsylvania. 25 And the records that were attached to the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 74 1 motion suggested that Jonathan had told the 2 Pennsylvania Bar that he was living in Gulf 3 Stream and that he was inactive. 4 And I think there was a case cited from the 5 Florida Supreme Court dealing with, whether or 6 not lawyers could operate in Florida, allegedly, 7 as a branch office of an out of state firm and on 8 what facts and conditions they could do so. 9 And the motion that was filed was a motion 10 to disqualify the O'Boyle Law Firm from handling 11 the case that was pending based on the argument 12 that it was not a bona fide interstate law firm. 13 That's my recollection of the motion. 14 But it would help if I could see it because 15 it was a couple years ago. 16 BY MR. O'BOYLE: 17 Q. Okay. But you did sign it, did you? 18 A. It would help if I saw it. I don't know if it 19 was electronically filed, if Joann signed it, I would 20 have to see it. 21 Q. Okay. So, are you denying you signed it? 22 A. Pardon? 23 Q. Are you denying you signed it? 24 A. I thought we just had this question. 25 Q. Perhaps we did. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 75 1 Are you denying you signed it? 2 A. I am not denying or admitting that I signed it 3 myself with my handwriting, I'm saying I would need to 4 see it. 5 Now, papers are filed electronically without me 6 signing them. In the old days, I had to sign things. I 7 had co -counsel. I don't know if Joann signed it or I 8 signed it without seeing it, I haven't looked at it in 9 some time. 10 Q. How many lawyers have you, for lack of a better 11 way of saying it, charged with the unlawful practice of 12 law? 13 A. You mean, have I charged? 14 Q. Filed any type of document, either directly with 15 the Bar or with the courts, how many? 16 A. I don't -- I don't think any. 17 Q. So, as far as Jonathan is concerned, 18 Jonathan O'Boyle -- let me say it differently. 19 Weren't you being vicious? 20 A. No. I think I was actually doing my job which 21 was to represent my client and take the position that 22 this law firm was not entitled to fees or to represent 23 the Plaintiff. 24 Q. Okay. 25 A. I don't think there's anything vicious in the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 W 1 motion at all. It purports to cite facts and law which, 2 I believe at the time I filed it, were in good faith and 3 still do. 4 Q. And why did you mention Judge Barkdull in the 5 scheme of my question which is, I only want the facts? 6 A. I answered that already. And I told you that I 7 was giving you a preface for how I got into the issue of 8 the -- of investigating the whole concept of 9 unauthorized practice of law. 10 I didn't say that Judge Barkdull's statements 11 were about to talk about the unauthorized practice of 12 law, although, that could be a fact as well because as a 13 judge making a statement, I don't know if that's a fact 14 or not. 15 Q. Now, I'm reading your document and you are 16 correct, it's titled Defendant's Motion to Disqualify 17 the O'Boyle Law Firm PC, Inc., in the alternative for an 18 evidentiary hearing. 19 Are you saying that the O'Boyle Law Firm, Inc. 20 was engaged in the unauthorized practice of law? 21 MR. GOLDSTEIN: I'm going to object. The 22 document speaks for itself. 23 THE WITNESS: I was saying that the -- I 24 think the motion says, and I'd love to have a 25 copy of it, but I'll give you my best answer Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 77 1 without it. As I recall the motion, it alleged 2 that the law firm was not a bona fide branch 3 of -- it was not an authorized law firm to 4 practice law because it was not a bona fide 5 branch of an genuine parent law firm. And I 6 cited a case that, I believe, was directly on 7 point. 8 BY MR. O'BOYLE: 9 Q. And you said it was not a bona fide law firm. 10 And that information, what is your factual basis it 11 wasn't magic? 12 MR. GOLDSTEIN: Ask and answered. 13 THE WITNESS: I had -- I had -- there were 14 attached to the motion, I believe, were documents 15 that bore out some of the things I said in my 16 answer. 17 BY MR. O'BOYLE: 18 Q. Well -- 19 A. There should be some attachments. 20 Q. Well, one of the things you said in your answer, 21 for a factual basis for him being practicing or engaged 22 in the unauthorized practice of law is his cell phone 23 number began with 561. Tell me how that correlates? 24 MR. GOLDSTEIN: Object to the form. 25 Mischaracterizes testimony. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 IS 1 THE WITNESS: The motion set forth a 2 position that in order for this law firm to 3 actually be a recognized Florida law firm, it 4 would have to be a branch of a bona fide 5 Pennsylvania law firm. 6 And the facts that were recited in the 7 motion, I believe, included materials from the 8 Bar that showed that Jonathan had indicated he 9 was not active in Pennsylvania. That showed that 10 he had reported to the Bar of Pennsylvania that 11 he lived in Gulf Stream. 12 The 561 number would be some evidence of the 13 fact that he was located in Florida. Some 14 evidence only because people do move with their 15 cell phones. 16 And I think the motion had other factors 17 that were recited in it, but I would have to see 18 it. There were exhibits attached to it. 19 But you said the motion said that Jonathan 20 was practicing law, unauthorized practice of law. 21 The motion didn't say that as I recall. The 22 motion said that Jonathan is permitted to be a 23 lawyer in Pennsylvania and practice law in 24 Pennsylvania. And he could have a parent law 25 firm in Pennsylvania and then have a branch Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 79 1 office, a bona fide office, in Florida, but that 2 wasn't what was happening here. 3 And that's what the motion -- that's why the 4 motion sought to disqualify the law firm. It 5 never sought any sanctions against 6 Jonathan O'Boyle. I'll look at it, but I don't 7 believe it did. 8 BY MR. O'BOYLE: 9 Q. When you said it didn't seek any sanctions, the 10 unauthorized practice of law is a felony, is it not? 11 MR. GOLDSTEIN: Object to the form. 12 THE WITNESS: The motion did not seek any 13 sanctions against Jonathan O'Boyle. The motion 14 was directed to the activity of a law firm and 15 that went to the issue of A, could the law firm 16 represent the law firm. 17 And B, was the law firm entitled to fees. 18 Now, as I recall -- well, I'll just let you 19 ask the questions. 20 BY MR. O'BOYLE: 21 Q. I'm looking at just one of your attachments. 22 A. You don't have a copy for me to look at while 23 you're reviewing these documents? 24 Q. Yeah, but I wouldn't give it to you anyway. 25 A. Okay. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 MR. O'HARE: Would you like us to go pose? 2 MR. HOCHMAN: Yes, I would like that. 3 MR. O'B0YLE: Okay. Let's all get up and go 4 pose. 5 THE WITNESS: Mr. O'Boyle, are you 6 adjourning the deposition? 7 MR. O'BOYLE: No, no, not at all. Counsel 8 asked us to go -- 9 MR. HOCHMAN: I didn't ask you, you 10 volunteered. 11 MR. O'BOYLE: And you said yes, you want me 12 to do it. 13 MR. HOCHMAN: Yes, if you want to. 14 THE WITNESS: I'm ready for your next 15 question, Mr. O'Boyle. 16 MR. O'BOYLE: Okay. 17 BY MR. O'BOYLE: 18 Q. The O'Boyle Law Firm PC, Inc., was that not a 19 Pennsylvania -- registered in Pennsylvania as a law 20 firm? 21 MR. GOLDSTEIN: Object to the form. 22 THE WITNESS: My -- I'd have to see the 23 document to see if it was PC, Inc., the dates, 24 but my general recollection is that it was 25 registered as a company in Pennsylvania. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 a 1 BY MR. O'BOYLE: 2 Q. Well -- 3 A. And I believe it was registered at a relative of 4 your family, some type of residential address if I 5 recall correctly, condo or townhouse. 6 Q. And what factual basis do you have that said you 7 can't be a Pennsylvania lawyer if your address for 8 notifications and mail is at a relatives? 9 A. That's not what I'm saying. 10 MR. GOLDSTEIN: Object to the form. 11 MR. O'BOYLE: Okay. Madam, would you be 12 kind enough to read back what Mr. Sweetapple 13 said. 14 THE COURT REPORTER: "That's not what I'm 15 saying". 16 MR. O'BOYLE: Go back. 17 THE WITNESS: If you can read the question 18 and answer, please. 19 (Thereupon, the last pending question and 20 answer was; after which the following proceedings 21 were had:) 22 THE WITNESS: Your question is, what 23 information do I have that you can't be a 24 Pennsylvania lawyer if your address for 25 notification is at a Pennsylvania relatives Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 address? 2 MR. O'BOYLE: Madam reporter, would you 3 kindly read the question back for Mr. Sweetapple. 4 THE WITNESS: Please. 5 (Thereupon, the last pending question and 6 answer was; after which the following proceedings 7 were had:) 8 THE WITNESS: I don't have any a factual 9 basis one way or the other for that. 10 BY MR. O'BOYLE: 11 Q. Okay. Was that in your motion? 12 A. I believe the motion made reference -- I believe 13 the motion made reference to -- to the fact that -- 14 Which fact are you asking me was in the motion? 15 Q. Madam -- 16 A. You said, was that in the motion. What do you 17 mean by that? 18 Q. What we were just talking about when you made her 19 read back multiple times. 20 A. What portion of it? The residency portion, the 21 townhouse portion, the portion that dealt with the -- 22 Q. They're all your answers. 23 MR. O'BOYLE: Madam, may I ask that you read 24 it back. I hope this will be the last one. 25 MR. GOLDSTEIN: Object to form. Strike the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 E, 1 commentary. 2 (Thereupon, the last pending question and 3 answer was; after which the following proceedings 4 were had:) 5 THE WITNESS: My answer is, I have no a 6 factual basis for that. 7 BY MR. O'BOYLE: 8 Q. Okay. That's fine. And thank you, 9 Mr. Sweetapple. 10 You say in your Defendant's Motion to Disqualify, 11 Jonathan O'Boyle has used the Pennsylvania professional 12 corporation to establish an office or other regular 13 presence in the State of Florida without being admitted 14 to practice here generally and thereby engaged in the 15 unlicensed practice of law. 16 What is your a factual basis for making that 17 statement? 18 MR. GOLDSTEIN: Document speaks for itself. 19 Object to the form. 20 THE WITNESS: In addition to what's in that 21 motion or just what's in that motion? 22 BY MR. O'BOYLE: 23 Q. Well, we'll start with what's with -- what's in 24 the motion. We'll start with that. 25 A. I think the motion referred to the number of Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 cases he was appearing pro hac vice in. 2 I'd have to see the motion and it's been some 3 time since I looked at it, a year. 4 Q. Well, you're understanding my word, are you not? 5 A. I understand -- I understand your words, but 6 you're asking me to recall beyond my ability to recall 7 is what I'm saying. 8 Q. Well, if you saw them or heard my words, what 9 would be the difference? 10 A. Well, there's a number of things -- you read one 11 paragraph in the motioned. I'd like to read the whole 12 motion to see what facts are in there. 13 Q. That's just what we're going to do. 14 A. Good. You told me you wouldn't show it to me, 15 but I'm glad you're going to. 16 Q. I'm not going to read the whole motion. 17 A. All right. That way if I had a copy, I could see 18 whether, in fact, you were reading the whole motion or 19 not. 20 Q. You said that several times. 21 A. That's the first time I think I've said that. 22 Q. I don't think so. 23 You say that Jonathan was an out of state 24 attorney who resided at his father's home in Gulf 25 Stream, Florida. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 PIR 1 What is the factual basis for saying that that 2 constitutes the unlawful practice of law? 3 MR. GOLDSTEIN: Object to form. Document 4 speaks for itself. 5 THE WITNESS: That's a fact that was cited 6 in the motion. 7 BY MR. O'BOYLE: 8 Q. I have the motion. You say it's a fact? 9 A. Yeah, that your son represented to the 10 Pennsylvania Bar that he was living in Florida and that 11 he was not active in Pennsylvania. 12 Part of the rubric for the interstate law firm 13 would have required that Jonathan or some lawyer be 14 practicing in Pennsylvania. And the case is cited, it 15 tells you. Lawyers can't come here from out of state 16 and practice law and say, oh, I have an office in New 17 York and they have abandoned their office in New York. 18 If that happened, every lawyer in the country 19 could come from wherever they used to practice and say, 20 I'm practicing here as a Florida lawyer. And when you 21 ask, where's your main office, just say, oh, it's a post 22 office box. There's really no lawyer there. 23 If you read the case that's cited, there has to 24 be a lawyer running a bona fide office that's a parent 25 company in order to sponsor an interstate law firm. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 And what I alleged, I believe, in the motion is 2 that before Jonathan was admitted in Florida, there was 3 a decision made to open the O'Boyle Law Firm in Florida, 4 that he was here full-time instead of waiting until he 5 passed the Bar to do that or instead of having some 6 other lawyer in Pennsylvania actually run a law firm in 7 Pennsylvania, that was the problem that was cited. And 8 that's what the attachments were filed to show. 9 Now, that's all I remember sitting here. I mean, 10 that's what I do remember sitting here. Unless you give 11 me more information. 12 Q. Who owned your office building where you keep 13 your offices? 14 A. That's my private financial information. I'm not 15 going to disclose that to you. I am not comfortable 16 talking about my assets, Mr. O'Boyle. 17 Q. It's public information, is it not? Isn't it on 18 the Palm Beach Tax Collector -- Tax Assessor's website? 19 A. The name of the entity? 20 Q. Yes. 21 A. I presume it is. 22 Q. Okay. So, who is it? 23 A. Sitting here, I couldn't even tell you the name 24 of the entity. I think it's the address, but I -- I'd 25 have to look. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 Q. Okay. 2 A. I think it's an LLC with the address. 3 Q. I see. And who's the tenant? 4 A. Who's the tenant? 5 Q. Yes. 6 A. My law firm occupies space there. Peter Sosa 7 occupies space there. Clients of mine occupy space 8 there. 9 Q. Okay. Do you know a lawyer named Kevin Tynin? 10 A. I don't believe I've ever met Mr. Tynin. I've 11 heard of him. 12 Q. Okay. Have you ever spoken to Mr. Tynin? 13 A. I believe -- I believe when I was -- yes, I 14 believe so or wrote to him. Spoke or wrote to him. 15 Q. Who? 16 A. Spoke or wrote. I believe I spoke, but I may 17 have only written to him. 18 Q. Okay. But you communicated with him? 19 A. In some form I communicated with him. 20 Q. And why would you contact Kevin Tynin? 21 MR. GOLDSTEIN: Object to the form. 22 THE WITNESS: Before filing the motion that 23 I filed, I saw -- I believe I saw some record 24 that referenced Mr. Tynin with regard to the 25 O'Boyle Law Firm. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 And I believe I either called or wrote him 2 with a series of questions about my concerns. 3 And I wanted to make sure I had his input with 4 regard to my investigation before I filed any 5 motion, if I can recall correctly. 6 BY MR. O'BOYLE: 7 Q. Generally stated, did he say that I agree that 8 Jonathan O'Boyle is engaged in the unlicensed practice 9 of law? 10 MR. GOLDSTEIN: Object to form. 11 THE WITNESS: No. 12 BY MR. O'BOYLE: 13 Q. What did he say? 14 A. I believe there's a letter. 15 Q. Okay. 16 A. And I'd have to see the letter to remember his 17 exact position. 18 Q. You don't remember one word? 19 A. I don't. I remember -- 20 Q. You've explained earlier that you had an 21 obligation, as an example, as a lawyer if you saw 22 somebody in violation of the rules, you'd have to report 23 it. 24 If Mr. Tynin said to you that Jonathan O'Boyle, 25 his activities are in violation of the rules, such as -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 I don't know if such as is right, the unlicensed 2 practice of law, you would have reported that, wouldn't 3 you? 4 A. I'm sorry? 5 Q. You would have reported that, would you not? 6 A. If Mr. Tynin would have said -- 7 Q. That, when you spoke to him, yeah, Jonathan 8 O'Boyle, I know him, he's engaged in the unlicensed 9 practice of law? 10 MR. GOLDSTEIN: Object to the form. 11 THE WITNESS: If I believed there was 12 evidence of that sufficient that it triggered my 13 ethical obligations, I would exercise my ethical 14 obligations. 15 BY MR. O'BOYLE: 16 Q. And when you say "evidence of that", Mr. Tynin 17 saying that to you, as a member of the Bar in the State 18 of Florida, you would discount what he said and look for 19 additional evidence, tell me? 20 A. This is all hypothetical. But if an attorney 21 told me another attorney was engaged in the unlicensed 22 practice of law, I would probably -- I know I would want 23 other facts and evidence before I would ever make an 24 ethical complaint. 25 I don't think I've made -- I can't remember any Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 US 1 ethical complaint regarding unlicensed practice of law. 2 I would not make that complaint without evidence. I 3 certainly wouldn't make it based on some lawyer saying 4 that without investigating it further. 5 Q. Do you know what kind of lawyer he is? 6 A. Mr. Tynin? 7 Q. Yes. 8 A. I don't know what kind of lawyer he is. 9 Q. Okay. 10 A. I think he's a Florida lawyer. 11 Q. Well, he is a Florida lawyer. And I think if you 12 did a little bit of due diligence, you would find that 13 he -- his practice is ethics. 14 A. I'm aware that Mr. Tynin holds himself out as 15 someone who has experience with Bar matters. There's no 16 such designation in the Bar that allows you to hold 17 yourself out as being an ethics council. There's no 18 certification for that. 19 But I know that he purports or suggests that he 20 has some experience in that area. 21 Q. Okay. 22 A. But I know that from the communication -- 23 Q. Okay. 24 A. -- I had with him. 25 Q. And did he, after your communication where he, I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 a 1 guess, wanted to know what your inquiry was, didn't he 2 call you to discuss Jonathan and didn't you not call him 3 back? 4 And if that's the case, would you consider your 5 conduct as being reckless lawyering? 6 MR. GOLDSTEIN: Object to the form. 7 THE WITNESS: You're refreshing my 8 recollection. I think that I indicated in the 9 correspondence that I proposed that all of our 10 communications be in writing so that I would have 11 a record of the communications because I was 12 making certain inquiries and I wanted a response 13 in writing. 14 BY MR. O'BOYLE: 15 Q. And what you're saying is, Mr. Tynin just 16 disregarded your requests, is that what you're saying? 17 MR. GOLDSTEIN: Object to the form. 18 Mischaracterizes his testimony. 19 THE WITNESS: No, I'm not saying that. 20 BY MR. O'BOYLE: 21 Q. What are you saying? 22 A. Just what I said. 23 Q. Can you say it again? 24 A. It's in the record. I am not going to repeat 25 myself. I've given you my testimony to your question. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 If you have another question, please ask it. 2 MR. O'BOYLE: Madam court reporter, can you 3 read back Mr. Sweetapple answer, please, and go 4 into my question? 5 (Thereupon, the last pending question and 6 answer was; after which the following proceedings 7 were had:) 8 THE WITNESS: I answered it. 9 MR. O'BOYLE: Okay. Then, can you go back 10 one question and we'll find out for sure if 11 Mr. Sweetapple answered it. 12 (Thereupon, the last pending question and 13 answer was; after which the following proceedings 14 were had:) 15 BY MR. O'BOYLE: 16 Q. Did you call Mr. Tynin back and say, I got your 17 phone message but I need to make sure everything is in 18 writing, so would you be kind enough to put whatever you 19 have to say in writing? 20 A. I don't recall. 21 Q. Do you have such a communication? 22 A. An oral communication or written communication? 23 Q. Well, written communication? 24 A. I remember there was an exchange of 25 communications in writing. I haven't seen them in over Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 93 1 two years, but I do recall there was an exchange. 2 Q. Did Mr. Tynin ever write you? 3 MR. GOLDSTEIN: Asked and answered? 4 THE WITNESS: I recall he did. 5 BY MR. O'BOYLE: 6 Q. Okay. And you didn't write him back, did you? 7 A. I think I wrote him and he wrote me back. 8 Q. Okay. When he -- that could be. 9 And did he write you again? 10 A. I'd have to -- I'd have to look at my file and 11 see all the correspondence that took place. I don't 12 remember. 13 Q. Did you investigate Jonathan O'Boyle? 14 MR. HOCHMAN: Before we go on to the next 15 line of questioning, I'd ask this as the second 16 excerpt with Mr. Tynin through the next excerpt 17 as request number two. 18 THE WITNESS: Pardon? Did I investigate 19 Jonathan O'Boyle? 20 BY MR. O'BOYLE: 21 Q. Yes. 22 A. I am not going to disclose my work product other 23 than the work product that's public record. And I think 24 you'll see printouts and other documents that I obtained 25 that are attached to the motion. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 Y An 1 Q. In your May 2, 2014 letter to -- 2 A. May I see a copy of it? 3 Q. No. To Jonathan O'Boyle, did you say in that 4 letter, during the course of my investigation? 5 A. I'd have to see the letter, but I don't think 6 I've ever written to Jonathan O'Boyle. You're talking 7 about Mr. Tynin. 8 Q. Talking about Jonathan O'Boyle? 9 A. You asked me about a letter I wrote to 10 Mr. Jonathan O'Boyle which I don't think I've ever 11 written to your son. 12 Q. Okay. Well, you're wrong. 13 A. Okay. 14 MR. GOLDSTEIN: Move to strike commentary. 15 THE WITNESS: If you can show me a letter, 16 maybe it will refresh my recollection. 17 BY MR. O'BOYLE: 18 Q. I understand. Generally stated, what we have in 19 this, what I'm going to call the corral, is a RICO suit, 20 some records suits, and a few others, such as this one, 21 slander suit, I think you said something about Cafi 22 suing you. I think that's what you said, would that be 23 correct? 24 A. What question are you asking me there? 25 MR. GOLDSTEIN: Object to form. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 95 1 BY MR. O'BOYLE: 2 Q. Okay. Is Cafi suing you? 3 MR. GOLDSTEIN: Asked and answered. 4 THE WITNESS: Cafi has sued my law firm. 5 BY MR. O'BOYLE: 6 Q. Okay. Is it suing you? 7 A. I don't think I'm a named Defendant in that case. 8 Q. Okay. You're familiar with the RICO suit which 9 rests in piece. That's a suit that you were heavily 10 involved in the preparation of, correct? 11 MR. GOLDSTEIN: Object to form. 12 THE WITNESS: I was involved in it. Heavily 13 is a term you used. I mean, I worked on that 14 case. 15 BY MR. O'BOYLE: 16 Q. Okay. And who did you work on the case with? 17 A. I worked -- Well, the lawyers that worked on the 18 case included Mr. Richmond, several lawyers in his firm, 19 Joann O'Connor, that's all I remember. 20 Q. Okay. So, that's all. No more lawyers? 21 A. There could have been more, I don't remember. 22 Q. Okay. So, it may have been more than five or 23 six? 24 A. Yeah. 25 MR. GOLDSTEIN: Object to the form. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M i 1 THE WITNESS: Mr. Richmond had a team of 2 lawyers that worked quite a bit on the case. 3 BY MR. O'BOYLE: 4 Q. Okay. Why, in this letter to Jonathan O'Boyle, 5 did you make this statement, "all Philadelphia residents 6 owe and must pay the city income tax regardless of where 7 they work". 8 A. That's a letter to Jonathan O'Boyle? 9 Q. Yes. 10 A. What's the date of that? 11 Q. Just asking about the statements? 12 MR. GOLDSTEIN: Object to the form. 13 THE WITNESS: That's -- why I make 14 statements is my work product. I am not 15 comfortable giving my work product. 16 It would have been a result of legal 17 research, I presume. 18 BY MR. O'BOYLE: 19 Q. Okay. Well, give me -- you are making a 20 statement in that letter that is certainly not 21 privileged? 22 A. I'm not claiming the letter's privileged, I'm 23 claiming -- First of all, I need to see the statement 24 because I don't know the context of it nor do I remember 25 it specifically. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 97 1 But what I'm saying to you is, why I would make a 2 legal statement or make a legal -- an inquiry regarding 3 a legal topic would be my thought process, my mental 4 impressions, my work product, a result of my research 5 and I'm not comfortable telling you why I make 6 statements or take positions. As a lawyer, I tell my 7 client's that generally not my opposing opinions. 8 Q. Give me your lay opinion? 9 A. My lay opinion of what? 10 Q. You say here, all Philadelphia residents owe and 11 must pay the city income tax regardless of where they 12 work. It's either work product, which you say it is and 13 I'm asking you just for your lay opinion as to what that 14 is? 15 MR. GOLDSTEIN: Object to the form. Asked 16 and answered. 17 THE WITNESS: I think it means what it says. 1B Sounds like it was a legal opinion I expressed, 19 not a lay opinion. Sounds like it was a legal 20 opinion I expressed. 21 But I told you, I'm -- even if I could 22 remember, I would not tell you the subject of my 23 research, who I spoke to, how I came to that 24 conclusion. That would be my mental impressions 25 and work product. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 BY MR. O'BOYLE: 2 Q. You say in this document -- 3 A. What document are you referring to? 4 Q. The one that I have in my hand. 5 A. Well, what is it? 6 Q. I'm only asking you about a statement you made. 7 You're saying to Jonathan, you swore that you were 8 domiciled and permanently resided in Long Port, New 9 Jersey. 10 Now, I'm just curious, why in the world would you 11 make such a statement? 12 MR. GOLDSTEIN: I'm going to object to the 13 form. If you want to have him answer questions 14 as to specific statements in the document, I'm 15 going to request that you show him the document 16 because I can't confirm what you're reading -- 17 that you're specifically reading is exactly set 16 forth in the document. 19 MR. O'BOYLE: Mr. Sweetapple? 20 THE WITNESS: I'd have to see the document 21 to know what was said, how it was said, to whom 22 it was said. You're reading things to me saying 23 that I said them. I don't even know that I said 24 them. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 Mr 1 BY MR. O'BOYLE: 2 Q. Okay. 3 A. Or that I wrote them. 4 Q. I understand. 5 MR. HOCHMAN: Mr. Sweetapple, my 6 understanding is that, he's asking you why and 7 you're asking him if you want me to answer why, 8 let me see the document for the context. 9 THE WITNESS: That's the only way I can 10 answer it. 11 MR. HOCHMAN: I understand. Mr. O'Boyle, 12 are you willing to give him the document? 13 MR. O'BOYLE: I am not. 14 MR. HOCHMAN: Okay. 15 MR. GOLDSTEIN: I'm just going to state on 16 the record that I'm going -- as a standing 17 objection to any line of questioning regarding a 18 document that he's currently questions about 19 based upon his refusal to provide the witness 20 with a copy. 21 MR. O'BOYLE: Madam court reporter and 22 Mr. Goldstein, Mr. Hochman, if it will make it 23 easier, I will accept a blanket objection on any 24 and every question. And after you get the 25 transcript, you can have a ball. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 ME 1 You don't have to make -- waste time. You 2 will have already made it. 3 MR. HOCHMAN: I am not sure the federal 4 civil procedure will allow me to do that with 5 you, who's a non -lawyer. 6 So, I would like that and I'll accept it, 7 but I am not certain I don't waive it. I'm 8 concerned about that. 9 MR. O'BOYLE: Well, I don't want you to 10 waive anything. Can you, maybe, during lunch, 11 can you make inquiry. It would just save us a 12 bunch of time, that's all. 13 MR. HOCHMAN: Well, I am not certain that if 14 I do that, that I'm not waiving something on 15 behalf of the Town. I'm uncomfortable with it. 16 I would suggest to you that the question 17 would go easier if you -- if you're going to ask 18 why would you say something in a document, that 19 you produce the document to the witness and he 20 can look at it and give you an answer. 21 The way that you're doing it, I would 22 suggest to you, doesn't help you. And I think 23 it's appropriate objection. And I think it will 24 go faster if you didn't ask a why question. 25 MR. O'BOYLE: Thank you. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 101 1 BY MR. O'BOYLE: 2 Q. Mr. Sweetapple, do you have any evidence that 3 Jonathan O'Boyle is currently domiciled in other than 4 Long Port, New Jersey? 5 A. I don't know where Jonathan O'Boyle is currently 6 domiciled. 7 Q. And so, that's a no, you have no evidence? 8 A. I have no evidence where he's currently 9 domiciled. 10 Q. Okay. And on May 2, 2014, which is the date of 11 this document that I know you dire highly want to see, 12 do you have any knowledge as it where Jonathan O'Boyle 13 was domiciled? 14 MR. GOLDSTEIN: Renew my objection. 15 THE WITNESS: As I sit here, I do not 16 recall. I would have to look at my files. 17 BY MR. O'BOYLE: 18 Q. Okay. 19 A. And my work product. 20 Q. Okay. Do you have any knowledge that Jonathan 21 O'Boyle does not currently reside in Long Port, New 22 Jersey? 23 MR. GOLDSTEIN: Asked and answered. 24 THE WITNESS: No. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 MCA 1 BY MR. O'BOYLE: 2 Q. When you communicated with Mr. Tynin, did you 3 speak about the UPL? 4 A. I don't remember speaking to Mr. Tynin. 5 Q. You don't remember ever speaking with him? 6 A. Not specifically. I told you, I don't know if it 7 was oral or in writing. 8 Q. Right. But forget the word specifically, do you 9 remember ever speaking to him? 10 A. No, I can't say that I remember having an oral 11 conversation with him. 12 Q. Okay. Have you ever heard of 2146 East 13 Huntington Street, Philadelphia? 14 MR. GOLDSTEIN: Form. 15 THE WITNESS: Is that an address that was 16 used in a writing? 17 BY MR. O'BOYLE: 18 Q. It is. 19 A. I can't specify a certain address without seeing 20 it. I don't relate that address to any specific thing 21 without seeing the writing. 22 Q. Okay. The writing -- and by the way, the letter 23 that I'm looking at has numbered paragraphs, essentially 24 bullets. 25 A. Who's the letter addressed to? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 103 1 Q. Pardon? 2 A. Who is the letter addressed to? 3 Q. I already answered that, but I'll read it again, 4 Jonathan O'Boyle, Jonathan O'Boyle, Jonathan O'Boyle. 5 A. It's addressed to him? 6 Q. Three times. 7 A. Okay. 8 Q. And the paragraphs or the content that I'm 9 talking about is in numbered paragraphs. And before 10 those numbered paragraphs it says, during the course of 11 my investigation, I noted the following matters. And 12 then after that you put in 11 paragraphs. 13 And paragraph number three, which has about ten 14 words, says 2146 East Huntington Street, address in 15 Philadelphia, seems to be a residential property owned 16 by a family member. 17 I know we talked about that address not in the 18 context of what I'm looking at now, but there's nothing 19 wrong with an address that you have on your, I guess, 20 registration or whatever, that's owned by a family 21 member, is there? made aware of and I 22 A. You already asked me that and you refreshed my 23 recollection because before I communicated in writing 24 with Mr. Tynin, I made inquiry of a Jonathan O'Boyle 25 regarding the facts that I have been made aware of and I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 104 1 asked him to respond to a series of questions. You 2 refreshed my recollection, I remember that. 3 Q. When you said "asked him", Jonathan? 4 A. Jonathan. I wrote Jonathan and before I -- 5 before I communicated with Mr. Tynin. 6 Q. Okay. 7 A. So, before I took any position in the motion, I 8 asked Jonathan his position with regard to topics and 9 then I remember some correspondence with Mr. Tynin. 10 So, if you would have shown that to me, you could 11 have refreshed my recollection a lot sooner. Thank you. 12 Q. Did you ever hear Johnstown, Pennsylvania? 13 A. I remember making some reference to it in some 14 writing. 15 Q. And do you have an idea what the content was? 16 A. Some allegation that -- or some evidence or some 17 fact that Jonathan had claimed that he was practicing 18 there, something like that. 19 Q. Was he practicing there? 20 A. I don't have any personal knowledge myself. 21 Q. Do you know anybody else who has personal 22 knowledge? 23 A. I am not going to divulge my work product to you 24 in terms of how I obtained evidence or what evidence I 25 obtained. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 105 1 Q. Do you think that's evidence where his office -- 2 where he has his office, do you think that's evidence? 3 A. Yes, I think that's something that's in that 4 motion, that was in that motion or ultimately was a 5 factor in the motion. 6 Q. It was certainly in the motion. 7 But wouldn't it be the case if this motion went 8 before a judge that your opponent, whether it be 9 Mitchell Burger, Elaine, John himself, wouldn't they ask 10 the question and wouldn't you have to answer -- in other 11 words, you wouldn't be able to say, work product, I'm 12 not answering. 13 Accusing a guy of UPL, but I am not telling you 14 why because it's work product. Do you think you would 15 get away with that? 16 MR. GOLDSTEIN: Object to the form. 17 THE WITNESS: I can't speculate. 18 BY MR. O'BOYLE: 19 Q. You can't speculate? 20 A. As to what would happen in a proceeding? No. 21 Q. Okay. When you were in college or law school, 22 mail or other important documents, did you receive them 23 in college and law school? 24 And let me just give you an example. You made an 25 application to law school while you were in college, I'm Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 106 1 assuming. Sometimes in college, things get misplaced or 2 slowed down and so on and so forth. 3 Did you give your address in college or did you 4 give your parents, your brother, your wife, if you were 5 married, as an address that you knew that someone would 6 receive it and call you up and say, Bob, we just got 7 your admission to A, B, C school, did you get those 8 important documents in college or did you get them at 9 someone's house that you knew was going to be vigilant? 10 MR. GOLDSTEIN: Object to the form. 11 THE WITNESS: Would you mind having that 12 read back? I counted seven questions. Don't 13 know which one you want answered. 14 BY MR. O'BOYLE: 15 Q. Okay. Let's start with number one and then we 16 can go right down to number seven. 17 A. Okay. Want to have her go number one, I think, 18 was whether or not I used -- why don't we read them, 19 read that back and I'll write them out with a piece of 20 paper and then I can try to answer them. 21 You want to have her read it back slowly for me. 22 MR. O'BOYLE: Yes. Young lady, would you 23 read back slowly for him. 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 107 1 (Thereupon, the last pending question was 2 read back; after which the following proceedings 3 were had:) 4 THE WITNESS: You want to know if I received 5 mail in college. Yes, I received mail in 6 college and I received them in law school. 7 Keep going. 8 (Thereupon, the last pending question was 9 read back; after which the following proceedings 10 were had:) 11 THE WITNESS: Yes, let me answer that. Yes, 12 I made application to law school. I was in 13 college. 14 Okay. What's the next question. 15 (Thereupon, the last pending question was 16 read back; after which the following proceedings 17 were had:) 18 THE WITNESS: In college, I had a residence 19 in Florida that was my domicile address. In law 20 school I had the same address, it was on my 21 driver's license. 22 My brother, I don't think I gave. I 23 didn't have a wife at the time. I didn't give my 24 parents. I did give my parents, I mean. In 25 college and law school, my address was 6800 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 Northwest 6th Street, Plantation, Florida, 2 33432. 3 (Thereupon, the last pending question was 4 read back; after which the following proceedings 5 were had:) 6 THE WITNESS: Any important documents came 7 to the address in college and law school that I 8 maintained which was my parent's address in 9 Plantation, Florida. 10 Did I answer your questions? 11 BY MR. O'BOYLE: 12 Q. I think so. 13 A. Good. 14 Q. Now, in connection with -- 15 A. And by the way, it's 12:25. Can we break for 16 lunch when you are done with this topic? 17 MR. O'BOYLE: We can do it right now. 18 THE WITNESS: Well, go ahead and finish the 19 topic, I'm not starving to death. 20 BY MR. O'BOYLE: 21 Q. Okay. Now, in your -- one or more of your 22 filings regarding Jonathan O'Boyle and the unpublished 23 practice of law, Jonathan -- if he were in college and 24 were -- or law school -- and by the way, I'm going to 25 use those interchangeably. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 109 1 If he were in college or in law school, it would 2 not be unusual for him to utilize his parent's address, 3 forgetting his mail, particularly his important mail 4 that he may be waiting for, would it? 5 MR. GOLDSTEIN: Object to the form. 6 THE WITNESS: Would it be -- would it be 7 unusual, is that the question. 8 BY MR. O'BOYLE: 9 Q. Yes. 10 A. I don't think so. 11 Q. Okay. Then, why did you raise it in your papers 12 that he was -- he was showing the Pennsylvania Bar that 13 his -- that his residence was in Florida? Why did you 14 raise that? 15 MR. GOLDSTEIN: Object to the form. 16 THE WITNESS: Asset forth in the motion. 17 BY MR. O'BOYLE: 18 Q. Okay. 19 A. And the case that was cited. 20 Q. Okay. So -- 21 A. It was evidence that there was no bona fide law 22 firm in Pennsylvania. There was only one lawyer in the 23 supposed Pennsylvania law firm; it was Jonathan O'Boyle. 24 He decided to tell the Pennsylvania Bar that he 25 was not actively practicing in Pennsylvania and that he Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 110 1 was living in Florida. That's not a law school get mail 2 situation, it's a statement he's made to the Bar where 3 he's actively practicing. 4 Then, in order to open up the O'Boyle Law Firm in 5 Florida, representations were made that it was a branch 6 of an active Pennsylvania law firm and it was being run 7 by Jonathan O'Boyle. Yet, Jonathan O'Boyle made 8 contrary representations, did not appear based on the 9 evidence that's put in the record, to have been 10 practicing and residing in Pennsylvania because he was 11 inactive there. 12 So, there's a case that's right on point that I 13 cited to the court. So, that's why I made that 14 reference. So, I'm giving you the benefits of my 15 analysis, it's in the motion. 16 BY MR. O'BOYLE: 17 Q. I'm looking attached to your motion -- 18 A. Excuse me, why are we talking about my motion in 19 a different case that's pending? 20 Q. Because that's what I want to do. 21 A. Okay. You haven't asked me one question about 22 slander or defamation since I've been here. 23 Q. Well, sounds like the deposition you took of me, 24 but I think you will find that I'm gaining great 25 knowledge here. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 111 1 A. That's not -- 2 Q. And I appreciate it. 3 I'm looking at a document that it's Exhibit C to 4 your Motion to Disqualify and it says, Jonathan was 5 admitted to the Bar on 11/13/2012 with a public access 6 address of 23 Hidden Harbor Drive, Gulf Stream, Florida. 7 Is there anything wrong with that? 8 A. I don't know. 9 Q. Give me your lay opinion? 10 MR. GOLDSTEIN: Object to the form. 11 THE WITNESS: I have no -- I have no 12 knowledge of anything wrong with what you just 13 said. 14 BY MR. O'BOYLE: 15 Q. Okay. 1001 Broad Street, Johnstown, 16 Pennsylvania, do you know anything about that address? 17 MR. GOLDSTEIN: Object to the form. Asked 18 and answered. 19 THE WITNESS: As I sit here now, no, I 20 don't. 21 BY MR. O'BOYLE: 22 Q. Okay. Do you think you ever knew anything about 23 that address? 24 A. I think it was something that was the subject of 25 a motion, letter, inquiry regarding the un -- the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 112 1 allegation that the O'Boyle Law Firm was engaged in the 2 unauthorized practice of law. 3 Q. And how would an address -- and of course it's an 4 exhibit to your motion, how would an address fit into 5 the unlicensed practice of law? It's not like you're 6 going to run around with a lottery ticket and say I won. 7 How would it will fit? 8 MR. GOLDSTEIN: Object to the form. 9 THE WITNESS: You want my legal opinion, you 10 want my work product or do you want me to recite 11 what's in the motion? 12 BY MR. O'BOYLE: 13 Q. I want your lay opinion. 14 MR. GOLDSTEIN: Object to the form. 15 THE WITNESS: I don't have a lay opinion. I 16 have a legal opinion. 17 BY MR. O'BOYLE: 18 Q. Then, give me your legal opinion? 19 A. I am not going to give you my legal opinion. 20 Q. Then give me your lay upon? 21 A. I don't have a lay opinion. My opinion is based 22 on my study of the law. 23 Q. Okay. And by the way, we can break for lunch 24 anytime at all? 25 A. I want you to, you know, finish the topic you're Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 113 1 on and then we can -- tell me when you are done and 2 we'll take a break and then we'll come back and start 3 something new. 4 MR. O'BOYLE: Well, I think I got, at least, 5 an hour. 6 THE WITNESS: On the unauthorized practice 7 of law? 8 MR. O'BOYLE: Yeah. 9 THE WITNESS: Well then, maybe you should 10 break for lunch. 11 MR. O'BOYLE: Okay. 12 THE WITNESS: Let's do that. 13 MR. GOLDSTEIN: I need to use the restroom. 14 So, let's just do that for a minute and then 15 we'll figure it out. 16 THE WITNESS: Let's take a two -minute break 17 and we'll talk and see how we're doing as far as 18 eating goes. 19 MR. GOLDSTEIN: Okay. 20 MR. HOCHMAN: Madam court reporter, do you 21 have a preference as to what we do? 22 THE COURT REPORTER: No. 23 (Thereupon, a recess was taken; after which 24 the following proceedings were had:) 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 114 1 BY MR. O'BOYLE: 2 Q. Bear with me for -- 3 MR. HOCHMAN: Are you ready to proceed? 4 MR. O'BOYLE: Give me just a moment. 5 (Thereupon, a recess was taken; after which 6 the following proceedings were had:) 7 MR. O'BOYLE: Did you say we were back on 8 the record? 9 MR. HOCHMAN: We tried, but then you said 10 you needed a minute. 11 MR. O'BOYLE: Ask for a minute and then you 12 get an hour. 13 Madam court reporter, are we now on the 14 record? 15 THE COURT REPORTER: Yes. 16 MR. O'BOYLE: Thank you. 17 BY MR. O'BOYLE: 18 Q. Mr. Sweetapple, have you ever heard of a young 19 lady, I say young lady, Ms. Michelle Gavagni, 20 G -A -V -A -G -N -I, does that name ring a bell with you? 21 A. No. 22 Q. Okay. Now, about Ms. Michelle Gavagni, Florida 23 Director of Board of Bar Examiners at 1891 Higher 24 Court -- 25 A. That's familiar. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 115 1 Q. That is familiar? 2 A. Yeah. 3 Q. Okay. And you wrote to her, didn't you? 4 A. I believe so. 5 Q. Okay. And what would you have written to her 6 about? 7 A. I believe that's confidential. 8 Q. A letter to the Bar on the unlicensed practice of 9 law? 10 A. I think any letters to the Board of Bar Examiners 11 are confidential, that's my understanding. 12 Q. Okay. I think you're incorrect. 13 And I'm going to ask you to answer it or if it 14 would make you feel better, when we do break, you could 15 check and confirm that I'm wrong or confirm that I'm 16 right and then we can go on, okay? 17 A. As you see fit. Ask me questions. I mean, 18 I'll -- 19 Q. Okay. Do you have a duty to report, I guess, 20 improper character to the Character and Fitness 21 Committee? 22 A. What Character and Fitness Committee? 23 Q. The one with the Bar Association, I'm sorry. 24 MR. GOLDSTEIN: Object to the form. 25 THE WITNESS: I'm unaware of a Character and Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 116 1 Fitness Association with the Bar Association. 2 BY MR. O'BOYLE: 3 Q. Okay. September 3, 2014, does that date ring a 4 bell with you? 5 A. I think that's the date of the settlement 6 conference and that was to be treated as mediation and 7 it was at my office, if I'm not mistaken. 8 Q. When you say "treated as mediation", as a matter 9 of law? 10 A. Are you asking me for my legal opinion? 11 Q. No. You just said an affirmative statement. 12 A. The statements -- I'm sorry, the agreements to be 13 maintained confidential, I think, as mediation or as a 14 mediation. 15 Q. But what's written on the piece of paper doesn't 16 necessarily carry the day, does it? 17 A. Are you asking me for my legal opinion? 18 Q. I'm asking you, you are the author and I'm asking 19 you? 20 MR. GOLDSTEIN: Object to the form. 21 THE WITNESS: What's on a written piece of 22 paper, does it always carry the day? 23 My legal opinion -- I'll give you my legal 24 opinion. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 117 1 BY MR. O'BOYLE: 2 Q. Okay. 3 A. Lawyers argue over documents all the time and are 4 interpreted differently all the time based on law, 5 facts. 6 Q. Okay. That September 3rd document or that 7 September 3rd meeting, or I guess you spoke, there is 8 just a document that emanated from that meeting? 9 A. There's a document that was signed before the 10 meeting. 11 Q. Okay. And who has that document? 12 A. I think everyone that was there got a copy of it, 13 I believe. 14 Q. Okay. And what went on during that meeting? 15 A. That was a private confidential settlement 16 discussion to be treated as mediation and I would not be 17 comfortable talking about that. 18 Q. Okay. And have you gotten a third party opinion 19 from a lawyer who has affirmed what you just said? 20 MR. GOLDSTEIN: Object to the form. 21 THE WITNESS: I wouldn't -- I wouldn't 22 disclose to you any opinions that I've gotten 23 from my client, from another lawyer. 24 BY MR. O'BOYLE: 25 Q. So -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 ME 1 A. It's privileged. 2 Q. So, there's really, then, no way that we could 3 know whether it's -- I am not sure I'm going to use the 4 right term, whether it's confidential except what you 5 said? 6 A. No. 7 Q. Okay. How else would we know? 8 A. Have the Judge determine it. 9 Q. Okay. But as of today, is it confidential or 10 not? 11 MR. GOLDSTEIN: Asked and answered. 12 THE WITNESS: My understanding is that it's 13 confidential. 14 BY MR. O'BOYLE: 15 Q. Okay. And your understanding is based on? 16 A. My understanding is based on my understanding of 17 the law. 18 Q. Okay. What was the meeting about? 19 A. I am not -- 20 MR. GOLDSTEIN: He's answered. 21 THE WITNESS: I am not going to disclose the 22 contents of the meeting. 23 BY MR. O'BOYLE: 24 Q. Was Mr. O'Hare there? 25 A. Mr. O'Hare was there. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 119 1 Q. Okay. Jonathan O'Boyle, his attorney, was he 2 invited there? 3 MR. GOLDSTEIN: Object to the form. 4 THE WITNESS: I don't know anything about 5 the communications between Mr. O'Hare and 6 Jonathan O'Boyle. 7 BY MR. O'BOYLE: 8 Q. Did you know that Jonathan O'Boyle was one of 9 Mr. O'Hare's counsel and was handling many of the 10 lawsuits against Gulf Stream on his behalf? 11 A. On August -- on September 3, 2014? 12 Q. September 3, 2014, yes. 13 A. Are you saying that Jonathan O'Boyle was 14 Mr. O'Hare's lawyer and represented him on numerous 15 matters that were pending? 16 Q. That's my recollection, yes. 17 A. I don't believe that Jonathan O'Boyle was a 18 member of the Florida Bar at that time, sir. 19 Q. Well then, I could be very wrong. The O'Boyle 20 Law Firm, they represented Mr. O'Hare in multiple 21 litigations at that time. 22 A. I believe they did present Mr. O'Hare in a number 23 of cases. 24 Q. Didn't you have an obligation to notify 25 Mr. O'Hare's counsel rather than put him in a meeting Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 120 1 and let him fend for himself? 2 MR. GOLDSTEIN: Object to the form. 3 THE WITNESS: You're asking me for a legal 4 conclusion? 5 BY MR. O'BOYLE: 6 Q. No. 7 A. I'm not going to give you my legal conclusion. 8 Q. Then, give me your lay opinion. 9 MR. GOLDSTEIN: Object to the form. 10 THE WITNESS: It's not a matter of a lay 11 opinion. I have a firm legal conclusion that I'm 12 not going to give you. 13 BY MR. O'BOYLE: 14 Q. Well, I'm entitled to your lay opinion. 15 A. I don't have a lay opinion. A lay person 16 wouldn't have a legal opinion on this. 17 Q. Okay. So, you think it's strictly a legal 18 opinion whether or not you invite a client's lawyer to a 19 meeting with the client, is that what you're saying? 20 MR. GOLDSTEIN: Object to the form. 21 THE WITNESS: No. 22 BY MR. O'BOYLE: 23 Q. What are you saying? 24 A. I'm trying to answer your question. 25 Q. Well, try again. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 121 1 A. Ask me the question again, I'll try again. 2 MR. O'BOYLE: Madam court reporter, I call 3 upon you. 4 (Thereupon, the last pending question was 5 read back; after which the following proceedings 6 were had:) 7 THE WITNESS: And my answer is the same, I 8 believe that ultimately is a legal opinion. 9 BY MR. O'BOYLE: 10 Q. Okay. Have you ever told anyone about that 11 meeting? 12 A. I am not going to discuss anything that I've 13 discussed with clients or staff. And I'm sure I've 14 discussed it with my client and staff. 15 Q. Well, let's go beyond that. Let's go to the 16 bowling alley. Let's go to -- 17 A. I'll answer one question at a time. I haven't 18 been to a bowling alley in some time, but I can safely 19 say no. 20 Q. Okay. How about at one of the clubs in Delray or 21 Gulf Stream? 22 A. No, I don't believe I've disclosed the content of 23 the confidential settlement discussion to anyone outside 24 in a club or anything of that nature. 25 Q. When you say, "anyone outside the club" -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 122 1 A. Anyone outside of the legal protected group, like 2 in the public is what I mean. 3 Q. Who is the legal protected group? 4 A. My staff, my associates, my co -counsel. 5 Q. I'm listening. 6 A. That's it. My client. 7 Q. Am I remembering right, that earlier you said 8 that a lawyer is obligated to report behavior that 9 violates the Bar rules to the Bar? 10 MR. GOLDSTEIN: Object to the form. 11 THE WITNESS: My answer's in the record. 12 BY MR. O'BOYLE: 13 Q. Would you answer again, please. 14 A. No, because I answered it two or three times 15 already. 16 MR. O'BOYLE: Counsel, would you ask 17 Mr. Sweetapple to answer? 18 MR. GOLDSTEIN: I believe he's answered the 19 question. 20 MR. O'BOYLE: I don't believe that he has 21 answered that question. 22 MR. GOLDSTEIN: I believe -- 23 MR. O'BOYLE: If you're instructing him not 24 to answer -- 25 MR. GOLDSTEIN: I'm not -- Mr. O'Boyle, I am Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 123 1 not instructing him. I'm telling you that he 2 answered that question several times now. 3 MR. O'BOYLE: Would you kindly certify that, 4 madam court reporter. 5 BY MR. O'BOYLE: 6 Q. Mr. Sweetapple, I'm going to ask you for your lay 7 opinion as to whether a lawyer is obligated to report 8 behavior that violates Bar rules to the Bar? 9 A. I don't have a lay opinion. 10 Q. You don't have a lay opinion, correct? 11 Okay. The September 3rd meeting in 2014 that we 12 just spoke about a few moments ago, Ms. O'Connor was 13 there, was she? 14 A. Yes. 15 Q. Okay. Did you have a duty to report her to the 16 Bar for her attendance in that September 3rd meeting? 17 A. You're asking me for my legal conclusion. 18 MR. GOLDSTEIN: Object to the form. 19 THE WITNESS: I will not give you my legal 20 conclusions. You're asking me for my legal 21 conclusions. 22 BY MR. O'BOYLE: 23 Q. Can I have your lay opinion? 24 A. I don't have a lay opinion. 25 Q. So, you strictly have a legal conclusion or legal Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 124 1 opinion which you won't answer and you do not have a lay 2 opinion just so I have it right, would that be right? 3 MR. GOLDSTEIN: Asked and answered. 4 THE WITNESS: Yes, that's exactly what I 5 just said. You just repeated what I just said. 6 BY MR. O'BOYLE: 7 Q. I just want to make sure that I got it right. 8 A. I can move closer to you if you need to hear it 9 or -- 10 Q. No, no, it's not a question of hearing, it's a 11 question of sometimes absorbing. And what I would hate 12 to do is to move forward, and it happens, what I would 13 hate to do is to move forward and assume an answer that 14 was not correct. I would rather confirm it which I 15 think is a reasonable, prudent thing to do. 16 A. All right. I would appreciate it if you would 17 have it read back rather than just repeatedly ask me 18 questions -- 19 MR. GOLDSTEIN: There's no question pending. 20 BY MR. O'BOYLE: 21 Q. Okay. Do you think your interactions with 22 Joel Chandler constitutes a conspiracy? 23 MR. GOLDSTEIN: Object to the form. 24 THE WITNESS: Does my interactions with 25 Joel Chandler constitute a conspiracy? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 125 1 BY MR. O'BOYLE: 2 Q. That was the question. 3 A. That would be a legal opinion and I'm not going 4 to give you my legal opinion. 5 Q. Okay. So, I take it that the answer is yes or 6 you don't know? 7 A. You can take -- 8 MR. GOLDSTEIN: Mischaracterizes testimony. 9 THE WITNESS: You want me to answer that or 10 is that a question? 11 BY MR. O'BOYLE: 12 Q. Your counsel interrupted us, but please answer. 13 A. So, your question is, you take that as a yes or a 14 what? 15 Q. I don't know? 16 A. That's your prerogative. That's not my answer. 17 Q. Your letter to the Bar, to Ms. Gavagni, like the 18 other letter you have numbered paragraphs, here there's 19 only four and I'm going to pick the shortest one. 20 A videotaped deposition and transcript of 21 Martin O'Boyle. Did I violate any of the Bar rules? 22 MR. GOLDSTEIN: Object to the form. 23 THE WITNESS: A videotaped transcript of 24 Martin O'Boyle? 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 126 1 BY MR. O'BOYLE: 2 Q. A videotaped deposition and transcript of 3 Martin O'Boyle. 4 A. In other words, did you violate any Florida 5 rules? 6 Q. Yeah. 7 A. That's a legal opinion and you're asking me for a 8 legal opinion. I'm not going to give you a legal 9 opinion. 10 Q. Okay. In your lay opinion, did I violate any of 11 the rules? 12 MR. GOLDSTEIN: Object to the form. 13 THE WITNESS: The Bar rules? 14 BY MR. O'BOYLE: 15 Q. Yeah. 16 A. I don't have a lay opinion concerning Bar rules. 17 Q. Okay. Why did you send Ms. Gavagni? 18 MR. HOCHMAN: Can you do me a favor, can you 19 spell that for me because you pronounced it a 20 couple different ways. 21 MR. O'BOYLE: G -A -V -A -G -N -I. 22 BY MR. O'BOYLE: 23 Q. Why would you send a transcript and video 24 deposition on me, another lawyer, to the Bar? 25 MR. GOLDSTEIN: Object to the form. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 127 1 THE WITNESS: I would presume -- I need to 2 see the letter, but I would presume there was 3 testimony in that document that concerned the 4 subject of the letter. 5 BY MR. O'BOYLE: 6 Q. Letter says, in furtherance of complaints, 7 plural, filed against Jonathan O'Boyle and the O'Boyle 8 Law Firm, I have enclosed the following; and there are 9 four items. 10 And then it says, we're forwarding these 11 materials to you in furtherance of the Town of Gulf 12 Stream complaint pursuant to our obligation under the 13 rules regulating the Florida Bar, 4-5.5 and 4-8.3? 14 MR. GOLDSTEIN: Object to the form. 15 Document speaks for itself. 16 THE WITNESS: What are you asking me about 17 the letter? 18 BY MR. O'BOYLE: 19 Q. Okay. 20 A. I'd like to see it to refresh my recollection. I 21 don't have a -- I haven't seen that in, I don't know how 22 long, years. 23 Q. Why did you forward the materials to Ms. Gavagni 24 at the Bar, why did you forward those materials? 25 MR. GOLDSTEIN: Object. Calls for a mental Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 128 1 impression, work product. 2 THE WITNESS: I'm not going to answer based 3 on legal communications with my client, my legal 4 opinion, my mental impressions. 5 BY MR. O'BOYLE: 6 Q. Can you give me your lay opinion? 7 A. I don't behave as a lawyer based on lay opinion. 8 I behave as a lawyer based on my legal opinions and 9 based on my instructions or communications with clients. 10 Q. But certainly you have lay opinions. I mean, 11 when you see a bowl of spaghetti, you don't look up case 12 law, you pick up a fork and you eat the bowl of 13 spaghetti, am I right? 14 A. Sometimes I use a spoon. 15 Q. Or a spoon, that's -- that's fine. Sometimes I 16 use a fork and a spoon. 17 A. Me as well. 18 Q. So, you do have lay opinions? 19 A. I think we all have lay opinions. 20 Q. Okay. 21 A. I don't have lay opinions about legal matters. 22 Q. Okay. In here you talk about an article 23 published by the Florida Center For Investigative 24 Reporting concerning the O'Boyle Law Firm and Citizens 25 Awareness Foundation, Inc. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 129 1 What was your objective in sending that to 2 Ms. Gavagni? 3 MR. GOLDSTEIN: And I'm going to object to 4 the form and again, renew my previous objection. 5 If you'd like to ask him questions about 6 statements made in the letter, I prefer you show 7 him the letter so that we can assure that what, 8 in fact, you are reading is accurate and he can 9 see the document that you're referring to. 10 MR. HOCHMAN: And let me just make another 11 statement. On behalf of the Town, if we want to 12 ask this witness questions about this letter at 13 trial, we're going to do that. 14 And if you choose not to inquiry based upon 15 having him look at the letter and doing it 16 appropriately, you do so at your parallel. 17 But I'm letting you know, if you object to 18 us questioning at trial, if there's a trial in 19 this case, going through the letter and step by 20 step, what his thinking was, you can either have 21 that opportunity now or we will take our position 22 at trial, okay. 23 MR. O'BOYLE: Thank you. 24 MR. HOCHMAN: Okay. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 130 1 BY MR. O'BOYLE: 2 Q. If I told you I had a copy of your September 3rd 3 document, would that be all right with you? 4 MR. GOLDSTEIN: Object to the form. 5 THE WITNESS: My September 3rd, what 6 document. 7 BY MR. O'BOYLE: 8 Q. The only document I know of September 3rd, the 9 one we spoke about a little earlier, the one that was 10 signed by -- something about mediation and so forth. We 11 talked about it earlier? 12 A. I -- 13 MR. GOLDSTEIN: Form. 14 THE WITNESS: I believe that's public 15 record. I don't think there's anything 16 confidential about the document. 17 BY MR. O'BOYLE: 18 Q. Okay. What would be confidential? 19 A. What the document says, what the parties were 20 meeting for, settlement conference to be treated as 21 mediation. Everything they discussed was to be 22 confidential and treated as mediation. 23 Q. So, that would be in the document then, would it 24 not? 25 A. No. If there was a settlement agreement at the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 131 1 end, that would be put in a document. That would, also, 2 be a public record. 3 But the oral communications that occur, the law 4 encourages settlement and confidential settlement 5 conferences so people can resolve their differences 6 without those matters being discussed outside that 7 setting and that's what we were attempting to do. 8 Q. Would you object if Mr. O'Hare, who was at the 9 meeting from recalling what you said, came forward and, 10 in fairness to all the parties, alerting the Bar 11 Association whatever and shared what was the content of 12 that September 3rd, what I'm going to call, the 13 mediation document? 14 A. That's a legal conclusion. It's a legal opinion. 15 MR. GOLDSTEIN: Object to the form. 16 BY MR. O'BOYLE: 17 Q. Okay. Would you personally object to it? 18 A. That's my legal -- it would depend on my legal 19 opinion. 20 Q. Okay. What is your lay opinion? 21 A. I don't have a lay opinion about legal matters. 22 Q. Okay. Mr. Chandler, there's a -- 23 A. By the way, it's about 1:15. So if, maybe, at 24 1:30 we can take a break at lunch, I'm starting to get 25 hungry now. So, 15 more minutes if you don't mind. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 132 1 MR. O'BOYLE: We can do it right now. 2 THE WITNESS: No, go ahead. I don't want to 3 interrupt you. 4 MR. O'BOYLE: You're not interrupting 5 because I'm going into something else that would 6 take a while. 7 THE WITNESS: Okay. It's a great time to 8 take a lunch. 9 MR. HOCHMAN: Right now, according to my 10 watch, it's now 1:11. 11 THE WITNESS: One hour. 12 MR. O'BOYLE: An hour-ish. Downstairs, you 13 just don't know what you're going to be 14 confronted it with. 15 By the way, are you buying? 16 THE WITNESS: No. If we ever settle, I'll 17 buy. 18 MR. O'BOYLE: The cameras are on and I just 19 don't want anybody to forget. 20 MR. GOLDSTEIN: He might hold you to it. 21 (Thereupon, a recess was taken for lunch; 22 after which the following proceedings were had. 23 MR. O'BOYLE: Are we on the record? 24 THE COURT REPORTER: Yes. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 133 1 BY MR. O'BOYLE: 2 Q. Mr. Sweetapple, how was it that you became 3 special counsel, as Mr. Morgan calls it, to Gulf Stream? 4 A. That requires lawyer/client communication. It's 5 privileged. 6 Q. Okay. Can you answer it other than a legal 7 fashion, as a laymen? 8 A. No, because what I was told was from the client 9 in anticipation or after being retained. 10 Q. I'm sorry? 11 A. No, I can't. 12 Q. And can you tell me why you can't? 13 A. Because it's privileged communication. 14 Q. As to why you were hired, that's privileged? 15 A. Everything the client told me was -- is 16 privileged. 17 Q. Okay. Now, if the client said what I just asked 18 in a newspaper, wouldn't he have waived the 19 communication, the privilege? 20 A. You're asking me for a legal conclusion, I can't 21 give you my legal opinion. I'm not here to give you my 22 legal opinions. I give those to Gulf Stream. 23 Q. Okay. Can you give me your laymen's opinion? 24 A. No. 25 Q. And why not? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 134 1 A. I don't think I have a laymen's opinion on the 2 law. 3 Q. Besides the law, you have no other laymen's 4 opinions? 5 A. I do, but not on the issue of waiver of 6 confidentiality. That's not a lay opinion, that's a 7 legal opinion. 8 Q. The RICO suit, were you part of the, I'm going to 9 say group of lawyers, who worked on and filed the appeal 10 of the 11th Circuit? 11 MR. GOLDSTEIN: Object to the form. 12 THE WITNESS: I -- I did not file the appeal 13 to the 11th Circuit. 14 And as to the work I did on the appeal, 15 that's lawyer/client privilege. 16 BY MR. O'BOYLE: 17 Q. If it's in your billings that are public records, 18 would that be attorney/client privilege? 19 A. Anything that's in my billing is a public record, 20 but I'm not going to discuss any work I did on -- the 21 nature of the work I did. 22 Q. But you did work on the appeal, would that be 23 correct? 24 A. If you take out the bills, it will show any 25 reference to the work -- time I spent on the appeal. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 135 1 Q. Is that a yes? 2 A. That's a yes. If you take a look at the bills, 3 you'll see any work that I did on the appeal. 4 Q. Okay. But you -- 5 A. Not the nature, but you'll see the time. 6 Q. But you did work on the appeal? 7 A. I did work on the appeal by virtue of reviewing 8 it. 9 Q. By virtue -- 10 A. Of reviewing it. I didn't write any of the 11 appeal. 12 Q. Okay. In your billings, the initials DPV, who iE 13 that? 14 A. That's David Paul Vitale. 15 Q. And who's ADV? 16 A. Alexander DeVargus. 17 Q. I see. Do you know when Mr. Vitale became 18 licensed in Florida? 19 A. I don't. Not by memory. 20 Q. Generally stated -- 21 MR. GOLDSTEIN: Asked and answered. 22 THE WITNESS: Trying to think when my 23 daughter -- it was after my daughter, but I don't 24 remember the -- I can't pick the month. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 136 1 BY MR. O'BOYLE: 2 Q. Okay. 3 A. I think it was the summer, sometime in the 4 summer. 5 Q. Of 1961? 6 A. 19 -- or 2000 -- maybe '14. I'm guessing. 7 MR. GOLDSTEIN: I don't want you to guess. 8 MR. HOCHMAN: I'm going to move to strike if 9 that's a guess. 10 BY MR. O'BOYLE: 11 Q. Do you know a fellow named Peter Isen? 12 A. Peter Isen? No. 13 Q. Okay. Well, he knows you. Are you sure you 14 don't know him? 15 A. I don't know him. I know who he is, but I don't 16 think I ever met him. 17 Q. Who is he? 18 A. I read that he was a resident -- if I'm not 19 mistaken, a resident of Long Port, New Jersey that you 20 sued after he said that you were the enemy of the people 21 of Long Port or something of that nature. And I read an 22 opinion concerning that as I recall. 23 Q. Of the 350 million people in America, where did 24 you find Peter Isen? 25 MR. GOLDSTEIN: Form. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 137 1 THE WITNESS: I'm not going to give my work 2 product, but in order to determine your past 3 conduct, you don't have to look up Peter Isen, 4 you just have to look up Martin O'Boyle. 5 BY MR. O'BOYLE: 6 Q. And you would find -- if you look up 7 Martin O'Boyle and you were looking to determine my past 8 conduct, you would find what by way of facts? 9 MR. GOLDSTEIN: Form. 10 THE WITNESS: You're asking me what's in the 11 public record about you? 12 BY MR. O'BOYLE: 13 Q. No. You said all we have to do if you want to 14 find out about Martin O'Boyle, you have to look him up. 15 A. No. I said, you don't have to know who Mr. Isen 16 is to find out about him. If you look at your past 17 record of activities, litigation, fights with towns, 18 mayors, banks, that you see names of people who you have 19 sued and conduct that you have engaged in. 20 Q. And the conduct that I have engaged in, do you 21 have any firsthand knowledge of that? 22 A. In other words, did I see it, was I there? 23 Q. No. Do you have any firsthand knowledge? 24 A. What do you mean by firsthand knowledge? 25 Q. Well, I'll ask it a different way. The conduct Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 that you speak of, are you relying on others to -- with 2 regard to determining that conduct with regard to your 3 sitting here now saying your conduct, you made that 4 statement and it came from somewhere? 5 A. Yes. I'm relying on others to -- witnesses, 6 reporters, judges who write opinions, I'm relying on any 7 number of people when I investigate a party's past 8 conduct. 9 Q. Did you find anything in any of the information 10 that you looked at that said that there's a glass 11 mountain of evidence, that phrase? 12 MR. GOLDSTEIN: Form. 13 THE WITNESS: Glass mountain of evidence. 14 That I found? 15 BY MR. O'BOYLE: 16 Q. Yeah. 17 A. Yes. When I investigated statements that you 18 made to the Town of Gulf Stream, you made reference to a 19 writing of a judge who I subsequently -- subsequently 20 recuse himself in a case that is on appeal currently, 21 and you made reference to a quote from a judge in an 22 order, I did see -- I did see that you put that in the 23 record. 24 That was, I think, at the time you went in there 25 and made comments about me which you subsequently Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 139 1 retracted on the record. 2 Q. So, the glass mountain evidence, that was about 3 you? 4 A. That was a statement by a judge that you 5 attributed to a judge when you were making derogatory 6 comments about me to the Town which you subsequently 7 retracted. 8 Q. Have you ever made any derogatory comments about 9 me? 10 MR. GOLDSTEIN: Object to the form. 11 THE WITNESS: I am not going to discuss my 12 communications with my client or my staff or my 13 counsel. 14 BY MR. O'BOYLE: 15 Q. Okay. Do you remember the question? 16 A. Yes. Have I made any derogatory statements about 17 you? 18 And to -- I'm sure I've made a derogatory comment 19 about you. 20 Q. Singular? Haven't you made multiple derogatory 21 comments about me? 22 MR. GOLDSTEIN: Object to form. 23 THE WITNESS: I would say that I have made 24 multiple derogatory comments about you. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 BY MR. O'BOYLE: 2 Q. Did you know that I had a white truck? 3 A. That you had a white truck? 4 Q. Yes. 5 A. No, I don't know if you have a white truck. 6 Q. Okay. Did you know that the Town towed my truck 7 in the first half of 2014? 8 A. I'm not going to disclose anything that my client 9 told me, but I recall -- I thought reading somewhere 10 that it was your wife's truck. I think I read a police 11 report or something that was a public record that said 12 it was your wife's truck. 13 Q. Ah -huh. 14 A. That was towed from somewhere. 15 Q. Whether my -- it was my wife's truck or my truck, 16 were you aware that the Town towed that in the first 17 half of 2014? 18 MR. GOLDSTEIN: Asked and answered. 19 THE WITNESS: At some point I became aware 20 that it was towed. How I became aware, I don't 21 remember if it was reading a police report, but I 22 did have communications thereafter that I am not 23 going to discuss with my client about the issue. 24 BY MR. O'BOYLE: 25 Q. Have you ever heard of a newspaper called the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 141 1 Gulf Stream Patriot? 2 A. I've seen a copy of the Gulf Stream Patriot maybe 3 one or more. I know I've seen at least one. 4 Q. And how did you get your hands on that? 5 A. How did I get my hands on it? 6 Q. Yes. 7 A. I don't remember. 8 Q. We talked about, I think we did anyway, banners 9 flying in the sky. Do you -- Now, I guess you've had 10 time to think about it, do you remember any of those 11 banners which may have applied to you? 12 MR. GOLDSTEIN: Form. 13 THE WITNESS: There's a pending motion with 14 regard to banners that you admitted you were 15 flying and there were a few that had my name or 16 referenced me, I believe. I do remember them. 17 BY MR. O'BOYLE: 18 Q. Okay. The pending motion, isn't flying a banner 19 a First Amendment right? 20 A. That's a legal opinion. 21 MR. GOLDSTEIN: Form. 22 BY MR. O'BOYLE: 23 Q. Okay. And you don't want to answer that, 24 correct? 25 MR. GOLDSTEIN: Object to the form. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 142 1 THE WITNESS: I can't give you my legal 2 opinion. It's a subject motion in court that's 3 going to be adjudicated at the end of the case. 4 BY MR. O'BOYLE: 5 Q. What does the -- if I were to find the motion, 6 what would it say about the banners? 7 MR. GOLDSTEIN: Form. 8 THE WITNESS: I think it related to conduct 9 that you had engaged in after the motion was 10 filed to disqualify the O'Boyle Law Firm. And 11 whether or not it was designed to intimidate 12 counsel from prosecuting that motion and fully 13 representing the Town. 14 And as you may know in litigation, there are 15 all types of restrictions courts can put on First 16 Amendment rights. 17 So, I believe there's an issue before the 18 court as to whether or not you and/or others in 19 the law firm were attempting to bully and 20 intimidate counsel by making a personal attacks 21 and flying a banners and that's the subject of a 22 motion. 23 I think that's been your conduct in 24 Long Port as well as the State Attorney to use 25 banners to attempt to intimidate or bully people. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 143 1 BY MR. O'BOYLE: 2 Q. Well, I'm glad you said think because that 3 clearly tells me that you don't know. 4 A. It's just my -- my lay observation. That's not a 5 legal observation, that's my lay observation that you do 6 that from having read what I've read. 7 Q. And what you read you could affirm is one 8 hundred percent true, correct? 9 A. I never believe what I read is a hundred percent 10 true. I always -- I have some scepticism. 11 I don't think the New York times is one 12 hundred percent true. I don't think the Congressional 13 Record is a hundred percent true. 14 So, I read as much as I can. I speak to as many 15 witnesses as I can. I try to corroborate. I try to be 16 as thorough as I can in my work, Mr. O'Boyle. 17 Q. I don't doubt that at all. But as far as these 18 banners, you have no factual knowledge that I am 19 responsible for those banners, do you? 20 MR. GOLDSTEIN: Form. 21 THE WITNESS: That's not true. 22 BY MR. O'BOYLE: 23 Q. Okay. Well, tell me what it is? Tell me what 24 your factual knowledge is? 25 A. Your attorney in open court admitted that you Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 144 1 were flying the banners. 2 Q. What attorney would that be? 3 A. Mr. Taylor is it? In front of Judge Barkdull -- 4 I mean, in front of Judge Peter Blanc. It's in the 5 record. 6 And I believe there was some other admission of 7 that. I don't know why you would be denying it. 8 Q. Did I deny it? 9 A. Well, you said you don't have any proof as if you 10 were challenging that it happened. 11 Q. Well, please don't tell me what I'm doing. 12 A. I'm not telling you what you're doing. 13 Q. You sure are. 14 A. I don't want to argue with me, Mr. O'Boyle. 15 Q. Sweetapple Silver Houses, LLC, have you ever 16 heard of that? 17 A. I heard -- yes, I have. 18 Q. And are you upset by that -- by the name of that 19 company? 20 A. Not upset. No, I'm not upset. 21 Q. Okay. What are you? 22 A. As a lay person, I see it as, yet, another 23 attempt that's consistent with dozens of incidents I've 24 seen where you've attempted to bully or intimidate 25 people into doing what you wanted and that's what I see Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 145 1 it as. It's pretty typical from what I've been doing 2 and predictable. 3 Q. And that's according to you, right? 4 A. I'm the one testifying. 5 Q. I understand that. But that's according to you? 6 A. I just said those things. 7 Q. But that's according to you, correct? 8 MR. GOLDSTEIN: Asked and answered. 9 THE WITNESS: If I said it, it would be 10 according to me, I didn't quote anybody. 11 BY MR. O'BOYLE: 12 Q. Okay. All right. If I would have opened some 13 sober houses and called them Sweetapple, LLC -- I'm 14 sorry, Sweetapple Silver Houses, LLC, would that have 15 troubled you? 16 MR. GOLDSTEIN: Asked and answered. 17 THE WITNESS: You're asking me to speculate. 18 BY MR. O'BOYLE: 19 Q. Just give me your laymen's opinion? 20 MR. GOLDSTEIN: Asked and answered. 21 THE WITNESS: I would be speculating. 22 BY MR. O'BOYLE: 23 Q. Pardon? 24 A. I would be speculating. 25 Q. How many sober houses have you built? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 A. I haven't built any sober houses. 2 Q. How many sober houses have you operated? 3 A. I haven't operated any sober houses. 4 Q. Do you know David Saffron? 5 A. David Saffron? I do not know David Saffron. I 6 know the name and I have spoken to him. 7 Q. So, then you do know him? 8 A. No. 9 MR. GOLDSTEIN: Object to the form. 10 THE WITNESS: I don't know him. 11 BY MR. O'BOYLE: 12 Q. Explain to me what's the difference between 13 speaking to someone and knowing someone in your mind, I 14 think that will save us some time? 15 A. I had a woman from China call me to ask me if I 16 was going to pay my American Express card. And I said, 17 I already have. I have no idea -- she told me her name, 18 but I have no idea what she looks like, I know -- I have 19 no idea about her family. 20 David Saffron I spoke to on the telephone on more 21 than one occasion. 22 Q. Did you send Mr. Saffron any documentation, 23 information, anything? 24 A. I believe I did. 25 Q. And what is it that you sent him? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 147 1 A. I would have to go back and look. 2 Q. Did Mr. Saffron send you anything by way of 3 documentation? 4 A. Yes, he did. 5 Q. He did. What did he send you? 6 A. I believe that's confidential and related to my 7 litigation. I'd have to go back and look, but that's my 8 recollection. 9 Q. And how would it be confidential? 10 A. It would be my work product and lawyer/client 11 work with regard to my matters. 12 Q. I see. But he did send you information? 13 A. Yes, he did. 14 Q. How many pieces of information did he send you? 15 A. I'd have to go back and look. 16 Q. Generally? 17 A. It wasn't very many. 18 Q. Very many, is there -- 19 A. Less than -- I mean, two, three, four. I mean, 20 I'd have to go look. 21 Q. Small amount? 22 A. Small amount. It was a brief period exchange, I 23 believe. 24 Q. How did you find Mr. Saffron in this $350 25 million -- million people country? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 MC 1 A. I don't remember. 2 MR. GOLDSTEIN: Form. 3 BY MR. O'BOYLE: 4 Q. How did Mr. Saffron find you? 5 A. I don't know if he found me or if I found him. 6 Q. I see. And if you did find him, you have no idea 7 how that happened? 6 MR. GOLDSTEIN: Asked and answered. 9 THE WITNESS: I have no idea as I sit here. 10 I could look through my files and see if it was 11 through a search that was done or I mean, a case 12 that his name appeared in. 13 As I sit here now, I don't know how learned 14 of him or he learned of me. 15 BY MR. O'BOYLE: 16 Q. Okay. Tom O'Donnie, do you know him? 17 A. I don't recognize that name. 16 Q. Patsy Randolph? 19 A. I recognize the name from depositions. I may 20 have met her. I have no idea sitting here today what 21 she looks like. I believe she's a resident of Gulf 22 Stream. 23 Q. Have you spoken to her? 24 A. It's possible because if she is one of the people 25 that's been at council meetings, I've had people come up Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 149 1 to me. I don't remember if it was her or not, but I 2 recognize that name. 3 Q. Is everything that you said at the council 4 meeting, to the public, true? 5 A. When? Are you talking about at council meetings? 6 Q. Yes. 7 A. I hope so. 8 Q. That's a yes or no? 9 MR. GOLDSTEIN: Object to the form. 10 THE WITNESS: To the best of my knowledge. 11 BY MR. O'BOYLE: 12 Q. To the best of your knowledge, everything you 13 said is true, correct? 14 A. When I report to the counsel, when I speak to 15 counsel members. 16 Q. When you speak in the -- Well, I'm going to call 17 the commission chambers to the people, to the commission 18 members, to the town manager, to the town clerk, to the 19 town attorney? 20 A. I assuming that the information I have is 21 accurate. I attempt to only tell the truth. 22 Q. Okay. Earlier on you said that you made some or 23 several derogatory comments about me. May I ask what 24 they were? 25 A. I can't remember the exact nature of them. Some Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 150 1 were with my wife, for instance, in private. Those are 2 privileged. I think I made one last night. So, I 3 wouldn't share them with you. 4 Q. Besides your wife, the one you made last night -- 5 excuse me, the one you made last night, I assume, was 6 not to your wife or was it? 7 A. To my wife. 8 Q. Okay. I see. 9 A. About what I thought you were doing in this 10 proceeding, for instance. 11 Q. I see, okay. The derogatory statements that you 12 made, you don't remember a one of them? 13 A. Actually, I do remember. I had a personal 14 conversation with my tennis partner last night. I am 15 not going to share it with you, but he's also a lawyer 16 and one of my lawyers. 17 But I did speak to him as to what I thought you 18 were about with regard to your conduct in this case 19 and -- 20 Q. And is that -- do you believe that to be 21 privileged? 22 A. Yes. 23 Q. Okay. And what is your basis for that belief? 24 A. Because he happens to be a lawyer and he 25 represents me. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 15] 1 Q. In this matter? 2 A. He represents me in general. He's my general 3 counsel. 4 Q. Okay. 5 A. Has been for twenty something years. 6 Q. But he doesn't represent you in this matter, is 7 that correct? 8 A. He's not counsel of record in this matter, but I 9 have discussed with him this matter. 10 Q. Okay. Do you have any documents that are 11 unsealed by a court? 12 A. Do I have any? 13 Q. Yes. 14 A. In my possession? 15 Q. Yes. 16 A. Not that I am aware of. 17 Q. Okay. 18 A. I mean, other than the fact I -- that we -- are 19 you talking about your case? Not yesterday we filed a 20 thousand pages in a case, I believe, unsealed in a -- in 21 the 15th Judicial Circuit. It was a different case. 22 Those we filed, I have those. 23 Q. As applies to myself and -- and/or to Mr. O'Hare? 24 A. Not that I am aware. I believe with regard to 25 Mr. O'Hare, there was a motion to file something Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 152 1 unsealed, but I don't think it's ever been filed and I 2 don't think I have a copy of whatever it was that was 3 being filed. 4 Q. Okay. Let's then limit it to just me. Do you 5 have any documents that are unsealed? 6 A. That's been filed unsealed? No. 7 Q. I don't know what filed unsealed means, but let 8 me try to use the best words that I can. Do you have 9 any documents that a court says you're not supposed to 10 have? 11 MR. GOLDSTEIN: Object to the form. 12 THE WITNESS: Not that I'm aware of. 13 BY MR. O'BOYLE: 14 Q. Did Peter Isen send you any documents? 15 A. I already answered that. Yes, he did. 16 Q. You didn't answer that, but that's fine. 17 And may I ask what he sent you? 18 A. It's confidential and privileged and work 19 product. 20 Q. Back to the derogatory statements that you said 21 about me; you said you told your wife and that's 22 privileged. 23 And you told your tennis buddy and you've 24 represented here that he is your counsel, has been 25 counsel for 25 years. And whatever you told him is Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 153 1 privileged, am I right so far? 2 A. And I spoke with, you know, staff, lawyers in the 3 office, my client. 4 Q. External to your client and their employees and 5 external to your 25 -year tennis partner who's your 6 lawyer, but not in this case, I mean, he hasn't entered 7 an appearance in this case, who else did you make 8 derogatory comments about me to? 9 A. I can't remember anybody offhand. 10 Q. Can't remember a sole? 11 A. No. 12 Q. Okay. Now, you said you made -- and I may not 13 have the right word, multiple -- you said you made 14 derogatory comments multiple times. And you may have 15 even said something with a higher element then that, 16 meaning a lot of times or whatever, but somewhere in 17 that arena. 1B Why didn't you just say two? 19 MR. GOLDSTEIN: Object to the form. 20 Mischaracterizes testimony. 21 THE WITNESS: For instance, my tennis 22 partner who I play tennis with two or three times 23 a week -- I've been involved with you for two 24 years. 25 So, I confidentially will say things to him Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 154 1 about what I think you're doing that are 2 derogatory, I think, can be taken as derogatory 3 right before I hit the tennis balls. 4 BY MR. O'BOYLE: 5 Q. What words or phrases would you characterize as 6 derogatory? 7 MR. GOLDSTEIN: Object to the form. 6 THE WITNESS: I'm not going to disclose the 9 terms that I've used. 10 BY MR. O'BOYLE: 11 Q. What words or phrases would you describe as 12 derogatory, except for those that you made to the Town 13 of Gulf Stream and any of its employees, except for 14 those that you made to your wife and except those who 15 you made to your tennis partner for 25 years who's been 16 your lawyer and still is your lawyer, and that's why 17 you're claiming a privilege? 18 MR. GOLDSTEIN: Object to the form. 19 THE WITNESS: You want to know what I 20 consider to be a derogatory comment? 21 BY MR. O'BOYLE: 22 Q. What you consider to be derogatory comments? 23 A. About another person? 24 Q. Well, you wouldn't -- unless it's about you, 25 which is not what -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 155 1 A. About any person, what would I consider to be 2 derogatory? 3 Q. Just in general, a derogatory comment? 4 MR. GOLDSTEIN: Form. 5 THE WITNESS: He's an ass. He's a fool. 6 He's a jackass. I mean, there are different 7 derogatory terms people use all the time about 8 other people. 9 BY MR. O'BOYLE: 10 Q. He's fucked up, is that a derogatory comment? 11 A. I've -- I would think so. 12 Q. Okay. He's a douche bag, is that a derogatory 13 comment? 14 A. I would think so. 15 Q. His head is in his ass, is that a derogatory 16 comment? 17 A. Yes. Although, the last three you quoted I hear 18 kids saying all the time. So, maybe now it isn't a 19 derogatory comment. Our society seems to be changing. 20 Now, Mr. Trump says things like that, so I guess 21 our world is really changing. 22 Q. Mr. Vitale, would he have any billings with your 23 firm or would you bill him out before 3/20/2015? 24 A. When he was a law clerk. 25 Q. And by the -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 156 1 A. He worked for me as a law clerk for some time 2 before he became a lawyer. 3 Q. And were you billing him out as a law clerk? 4 A. Yes. As a law clerk, yes. 5 Q. And what was the rate that you were billing him 6 out at? 7 A. I don't remember. 8 Q. What does, generally, a law clerk -- 9 A. I'd have to look and see. Mr. Vitale graduated 10 number two in his class from BC Law. He's a three-year 11 CPA. He's now working at a large New York firm making 12 twice -- You know, a lot more than I paid him and I was 13 paying him top dollar. 14 So, I mean, I don't know -- I don't remember what 15 his rate was. But, you know, he's he a top tier lawyer. 16 Q. At this point, though, he was not a lawyer? 17 A. At this point he was a CPA and was awaiting his 18 Bar -- getting sworn into Bar. He was -- he graduated 19 from law school. He was not yet sworn in. 20 Q. Did you ever slander me, Mr. Sweetapple? 21 A. That's a legal conclusion, but don't believe I 22 did, no. 23 Q. And what makes you not believe that you did? 24 A. Because I don't believe I did. I am aware of 25 what slander is and I don't believe I ever slandered Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 157 1 you. 2 Q. Isn't that a legal conclusion of what slander is? 3 A. I told you, I don't believe I have. I think 4 it's -- it's a legal conclusion. 5 Q. Okay. What would you expect a paralegal to bill 6 at? 7 In other words, if you looked at another lawyer's 8 bills, which I'm sure you do -- 9 A. I would say 150, 250. For a paralegal, you're 10 not talking about a graduate law clerk. I mean, 11 Mr. Vitale worked with the Federal Judge in Boston who 12 did the Boston Bomber Trial, for instance. 13 I mean, you're talking about a first year law 14 clerk, second year law clerk, paralegal, that's a 15 different concept then someone who's graduated from law 16 school who's worked in Federal Court, who's, you know, 17 highly talented and -- depends on who the person is. 18 You can be a paralegal without even going to -- 19 you can call yourself a paralegal without even having 20 gone to paralegal school. 21 Q. Now, I know what these two fellas, Mr. Hochman, 22 Mr. Goldstein bill at. And I'm looking and I believe, 23 and unless I'm mistaken, that Mr. Vitale billed at more 24 than them. How could that be? 25 A. Billings are a function of the type of work you Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 do. For instance, I bill at 350 an hour for Gulf 2 Stream, I believe. My billing rate is 650 an hour. It 3 depends on who the lawyer is, what the firm is. 4 Insurance defense lawyers bill at very, very low 5 rates in the industry. So, you'll see insurance defense 6 lawyers billing at 150, 125. I billed at 125 in 1980. 7 So, it's typical in the industry that insurance 8 defense lawyers, because they do volumes of work, it's 9 negotiated with carriers, small firms, big commercial 10 firms, private firms that do the type of work that we do 11 bill more at the rates we do. It's the function of the 12 type of firm, the type of lawyers that are involved. 13 Q. But if a top lawyer can bill at 650 -- 14 A. That's not the top rate. I mean, Mr. Grossman 15 bills much higher than I do. 16 Q. No, a top lawyer, a seasoned lawyer can bill at 17 650, why would a good lawyer bill 125, 150? Is it 18 because they can't get work otherwise? 19 MR. GOLDSTEIN: Asked and answered. 20 THE WITNESS: No. You're asking my opinion 21 from the -- my experience with the law. It's not 22 really a legal opinion, it's an informed business 23 opinion. 24 But I have seen the big insurance firms bill 25 at very low rates with very high volume, very Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 159 1 large use of paralegals, young lawyers. 2 You can get a job at the State Attorney's 3 Office and make $45,000 a year and you're really 4 billing out at $50 an hour when you add it up. 5 Really depends on the setting you're in. 6 BY MR. O'BOYLE: 11 7 Q. Gotcha. Before Mr. Vitale was a lawyer, he was 8 billing at 200 an hour, does that sound right? 9 A. I would have to look. 10 Q. Okay. After Mr. Vitale was a lawyer, he was 11 billing at 200 an hour, does that sound right? 12 A. It could be. Could be. him at 13 Q. Who determines what the billing rate is? 14 A. His billing rate, after he became a lawyer, was 15 300 or 275 or 325. But because Joann O'Connor was 16 billing at a discounted rate as a courtesy to the 17 client, I did not bill him at the firm's rate. 18 So, you mentioned yesterday that I made $600,000 19 representing Gulf Stream, which I never added up, and 20 you thought it was outrageous. I looked at it as how 21 much I've lost in revenue because both Mr. Vitale and 22 myself were not billing at our full rates and I have 23 more than enough work to handle at 650 an hour, but 24 because I committed to take the case at 350 because it 25 was a government, I've continue to bill at that way. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 However, it's consumed much more time than I ever 2 expected and gone much longer than I ever expected. 3 So, I probably have, in terms of my business, if 4 I ever did look at my income and statements, which I 5 don't focus on, I would probably see that I've lost 6 money representing the Town of Gulf Stream frankly. 7 Q. When you say it took much longer than you 8 expected, could I read into that that you thought you 9 were going to crush myself and Mr. O'Hare long before 10 this? 11 A. No. 12 MR. GOLDSTEIN: Object to the form. 13 THE WITNESS: You can read into that that I 14 never knew who Mr. Chandler was and I never 15 expected anything like this would develop in the 16 case when I got into it. 17 Absolutely could not have predicted a 18 witness like Joel Chandler contacting me and 19 hearing what I have heard; that was totally 20 beyond anything I ever expected when I got 21 involved in this litigation. 22 BY MR. O'BOYLE: 23 Q. If Mr. Chandler said that the Town's conduct was 24 criminal, would you agree with him? 25 A. If -- you're asking me a hypothetical. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 161 1 Q. No -- 2 A. You're also asking me for a legal opinion and I 3 am not going to give you my legal opinion. 4 Q. Well, then give me a non -legal opinion? 5 MR. GOLDSTEIN: Form. 6 THE WITNESS: I don't think -- I don't think 7 I offer non -legal opinions on those subjects. 8 BY MR. O'BOYLE: 9 Q. How many people have you said that -- have you 10 told that I was a criminal? 11 A. I have not said Martin O'Boyle is a criminal. 12 Q. Have you said Marty O'Boyle is a criminal? 13 A. No, I haven't. 14 Q. Have you made Martin -- or I'm sorry, 15 Mr. O'Boyle is a criminal? 16 A. No, I haven't. 17 Q. I see. And have you ever said that I was an 18 extortionist? 19 A. I don't believe so. I've never said that. 20 Q. Well, certainly in the papers, the RICO suit, you 21 said that? 22 A. I didn't file the RICO suit. 23 Q. I didn't say you did. 24 A. So, why are you saying that I said what's in the 25 papers that were filed by the Richman Greer Firm? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 162 1 Q. Because you participated in the preparation -- 2 A. You're saying -- 3 Q. And you said that you reviewed them or you 4 reviewed it? 5 A. I said I reviewed the appeal, but I did work on 6 the RICO case. 7 Q. Okay. 8 A. To say that I wrote Martin O'Boyle is an 9 extortionist, I don't believe I've ever even written 10 that in a legal paper. 11 Q. And why haven't you? 12 MR. GOLDSTEIN: Form. 13 THE WITNESS: Why haven't I written it in a 14 legal paper? 15 BY MR. O'BOYLE: 16 Q. Yes. 17 A. Because, I don't know. 18 Q. Is it because you don't believe it? 19 MR. GOLDSTEIN: Form. 20 THE WITNESS: I am not going to discuss my 21 beliefs and my legal opinions with you. 22 BY MR. O'B0YLE: 23 Q. Have you ever used, in the same sentence, my name 24 with criminal? 25 MR. GOLDSTEIN: Asked and answered. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 163 1 THE WITNESS: I believe that I have in 2 discussions with Mr. Hannah stated to him that 3 Mr. Chandler contacted me saying that he was 4 alleging that you and others were engaged in 5 criminal and fraudulent behavior. 6 I have said to him, such as, if what 7 Mr. Chandler is saying is true, he appears to be 8 alleging a scheme to defraud under Florida 9 Chapter 817 which is a criminal statute. 10 I have discussed in terms of discussing this 11 alleged scheme that Mr. Chandler told me about 12 with Mr. Hannah what the legal ramifications of 13 the allegations would be, we've debated that. 14 BY MR. O'BOYLE: 15 Q. Did Mr. Hannah talk about what occurred at the 16 September 3rd meeting? 17 A. Where? 18 Q. Well, the same one we've been talking about, the 19 September 3rd meeting, the mediation? 20 A. But where? Did he talk after it or before it? 21 Q. Well, he would have had to talk -- Well, after 22 it? 23 A. Did he talk to me after it? 24 Q. No, I didn't say that. Did he talk -- do you 25 have any knowledge that Mr. Hannah, after the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 164 1 September 3rd meeting, disclosed what occurred during 2 the September 3rd meeting? 3 A. To his client? 4 Q. Please don't change the question. 5 A. Disclosed -- I don't have any -- I don't have any 6 personal knowledge. 7 Q. Did you take his deposition? 8 A. I took his deposition. 9 Q. And in his deposition didn't he say that? 10 A. I don't remember. I don't remember. 11 Q. If he did say it, it's now fair game, you agree 12 with that, do you not? 13 MR. GOLDSTEIN: Object to the form. 14 THE WITNESS: What's fair game? 15 BY MR. O'BOYLE: 16 Q. What happened in that meeting? 17 A. That's a legal conclusion. 18 Q. Okay. It would no longer be privileged, would 19 it? 20 A. That's a legal conclusion. 21 Q. So, it might still be privileged, even though 22 there's a transcript out there, it's on the internet, it 23 still may be privileged? 24 A. Yeah. In terms of privilege, yes, yes, it's -- 25 Q. Okay. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 165 1 A. Things can be discussed in deposition and still 2 not admissible. It could be a violation of an 3 agreement. You're asking me legal conclusions, but 4 that's my -- that's what you're getting at. 5 Q. Well, once it's on the internet, isn't it hard to 6 un -ring the bell? 7 MR. GOLDSTEIN: Object to the form. 8 THE WITNESS: I don't know what you mean. 9 BY MR. O'BOYLE: 10 Q. Okay. Once something is -- say his video 11 deposition was put on the internet. What he said at 12 that deposition would be disclosed to the world, am I 13 correct? 14 A. I would presume anyone could see it, yeah. 15 Q. Okay. So, whatever privilege is or whatever did 16 attach or secrecy, or whatever the mediation word meant, 17 it's gone, isn't it? If I'm correct, that it's on the 18 internet? 19 MR. GOLDSTEIN: Asked and answered. 20 THE WITNESS: That's a legal conclusion. 21 BY MR. O'BOYLE: 22 Q. That is a legal question? 23 A. Yes. 24 Q. Okay, that's fine. You were hired by Gulf Stream 25 in March or April of 2014, does that sound right? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 A. It does. 2 Q. Okay. And what was the scope of your duties as 3 they announced it solely in public? 4 A. I wouldn't know. I wasn't in public when they 5 announced it. 6 Q. How did you find out what your duties were? 7 A. My duties have been discussed with my client. 8 Q. Have your duties at all changed? 9 A. I wouldn't feel comfortable discussing my 10 communications with my client in that regard. 11 Q. I am not asking you to. I just asked if you're 12 duties have changed? 13 A. That would be lawyer/client privilege. 14 Q. Well, your duties could change unilaterally? 15 A. Well, my -- 16 MR. GOLDSTEIN: Form. 17 THE WITNESS: My duties are a function of my 18 discussions with my client. I am not going to 19 reveal my discussions with my client. 20 BY MR. O'BOYLE: 21 Q. Now, we're dealing with a government and I'm 22 looking for the scope of your duties. 23 And the reason I am is, your duties as they were 24 initially discussed by the commission and where they are 25 now is far field, you're in a different planet. And I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 167 1 just want to know how they changed? When did they 2 change? If it's a -- if it's privileged, I understand. 3 A. Well, first of all -- 4 MR. GOLDSTEIN: Form. 5 THE WITNESS: -- I don't agree with your 6 characterization. 7 Second of all, my communications with the 8 client are privileged. 9 BY MR. O'BOYLE: 10 Q. Why don't you agree with my characterization? 11 A. Because you said something about a different 12 planet. I don't think we're on a different planet at 13 all. I think we're dealing with my scope of 14 representation as it applied to the facts that developed 15 during litigation. 16 During litigation, facts come out and you apply 17 your lawyering and the scope of your representation to 18 those facts. 19 Q. If you're fees are 650 an hour and if Mr. Vitale 20 was normally billing over 300, I think you said? 21 A. Somewhere in that range, I don't remember. 22 Q. Yeah. You said that you were losing money? 23 A. Yes, because I -- you're asking me a question. 24 Yes, because what I'm doing every month is working much 25 more on Gulf Stream matters then I expected and not Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 billing clients that routinely pay me a lot more money. 2 But I've made a commitment to take the case and 3 I'm going to see the cases through. I didn't expect to 4 have you -- have someone sue me personally twice, the 5 law firm twice. 6 Although, based on what I know about your past 7 conduct, I shouldn't be surprised. 8 Q. And I am not sure what that means whether you're 9 talking about a glass mountain, whether you're talking 10 about filing a bullshit claim against my son for the 11 unlicensed practice of law, I don't know. 12 MR. GOLDSTEIN: There's no question pending. 13 Is there a question? Otherwise, I'm moving to 14 strike your comments. 15 BY MR. O'BOYLE: 16 Q. In connection with this litigation, are you 17 claiming immunity? 18 A. That calls for a legal conclusion and work 19 product, but I'd have to look at the pleadings that were 20 filed by my counsel to give you the best answer on that 21 regard. 22 Q. If you'd like to take sixty seconds and ask your 23 counsel -- 24 A. If you show it to me -- I'm not going to speak to 25 my counsel right now. If you show me the pleadings, I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 169 1 can read it. 2 Q. Okay. We'll ask a different question. 3 Are you not claiming immunity? 4 MR. GOLDSTEIN: Object to form. 5 THE WITNESS: Same answer. 6 BY MR. O'BOYLE: 7 Q. Okay. So, you don't know? 8 A. Well, I saw the pleading some time ago. There 9 were a number of defenses plead. I don't remember -- I 10 remember absolute immunity, I think, and qualified 11 immunity as I recall. 12 Q. I'm just referring to, are you claiming immunity? 13 A. Well, I think the pleading refers to -- I think 14 it uses the term absolute immunity and qualified 15 immunity if I'm not mistaken, but I'd need to see it. 16 Q. But qualified, the next word is immunity? 17 A. Yes. 18 Q. Absolute, the next word is immunity? 19 A. Right. 20 Q. My question is, are you claiming immunity? 21 MR. GOLDSTEIN: Asked and answered. 22 THE WITNESS: I think the pleading has those 23 two affirmative defenses in it if I'm not 24 mistaken. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 170 1 BY MR. O'BOYLE: 2 Q. Okay. So, you're claiming immunity? 3 A. My lawyer has asserted those defenses in a 4 pleading on my behalf is my best recollection. 5 Q. Gotcha. 6 A. I'm going to want to take a break in five or 7 ten minutes, so just -- 8 Q. Did you ever say to Ms. O'Connor about me and my 9 son that you're going to get me by going after my son? 10 MR. GOLDSTEIN: Object to form. 11 THE WITNESS: Well, I am not going to 12 disclose any communication with Ms. O'Connor. I 13 mean, anything I discuss with Ms. O'Connor is 14 confidential. 15 BY MR. O'BOYLE: 16 Q. Unless it was heard by a third party, isn't that 17 correct? 18 A. That's a legal conclusion. It depends on how it 19 was heard, who heard it. That's a legal conclusion. 20 Q. Okay, I see. So, if someone else heard it, it 21 may not be privileged and you're not going to answer? 22 MR. GOLDSTEIN: Object to the form. 23 THE WITNESS: I'm not going to speculate. 24 But as to any communications I've had with 25 Ms. O'Connor, even if they're entirely invented Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 171 1 in your question, I'm not going to answer. 2 BY MR. O'BOYLE: 3 Q. Well, they're not invented and there's no glass 4 mountain of evidence. 5 A. Do you have a question? 6 MR. GOLDSTEIN: Move to strike. 7 MR. O'BOYLE: You said made a statement and 8 I was just responding. 9 MR. GOLDSTEIN: He was responding to your 10 statement. Move on, please. 11 THE COURT REPORTER: Can we take a break? 12 MR. O'BOYLE: Sure. 13 (Thereupon, a recess was taken; after which 14 the following proceedings were had:) 15 MR. O'BOYLE: We're back on the record, are 16 we? 17 THE COURT REPORTER: Yes. 18 MR. O'BOYLE: Mr. Hochman, I am told that 19 Ms. Randolph is supposed to be here for 20 deposition at 4:30 this afternoon and that it was 21 arranged through you, is that correct? 22 And do you, to your knowledge, will she be 23 here? 24 MR. HOCHMAN: I don't know. 25 MR. O'BOYLE: You don't know if it's Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 172 1 correct? 2 MR. HOCHMAN: I don't know if it's correct 3 and I don't know if she'll be here. 4 MR. O'BOYLE: Okay. You don't know whether 5 it was made through you? 6 MR. HOCHMAN: I know it wasn't made through 7 me. 8 MR. O'BOYLE: It was not? 9 MR. HOCHMAN: That's correct, it was not 10 made through me. 11 MR. O'BOYLE: If you'd give me one moment. 12 I was -- Mr. Goldstein, was it made through you? 13 MR. GOLDSTEIN: Most certainly not. 14 MR. O'BOYLE: Okay, okay. 15 MR. GOLDSTEIN: I have never had a single 16 discussion with Ms. Randolph in my life. 17 MR. O'BOYLE: I will alert the media. 18 MR. HOCHMAN: Do you have service on her? I 19 tried to ask this question at the very beginning 20 of this deposition. 21 MR. O'BOYLE: You certainly did. 22 MR. HOCHMAN: Do you have a return of 23 service indicating that Ms. Randolph was served 24 with process? 25 MR. O'BOYLE: My understanding is, and we'll Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 173 1 get it resolved this very second. 2 MR. HOCHMAN: Okay -- 3 MR. O'BOYLE: -- is that one of you two, it 4 was made through one of you two. 5 MR. HOCHMAN: That is not possible. 6 MR. GOLDSTEIN: I would agree. 7 MR. O'BOYLE: Okay. 8 MR. HOCHMAN: We have no authority to accept 9 a subpoena for a resident of the Town of Gulf 10 Stream. 11 MR. GOLDSTEIN: Nor am I. 12 MR. O'BOYLE: Is the other fellow there? 13 (Thereupon, Mr. O'Boyle is on the 14 telephone.) 15 MR. HOCHMAN: Do you want to put it on 16 speaker so we can all hear? 17 MR. O'BOYLE: No, privileged, work product. 18 MR. HOCHMAN: Since you got your law 19 license, Mr. O'Boyle? 20 MR. O'BOYLE: Are you not allowed to have 21 privilege unless you have a law license? 22 MR. HOCHMAN: Well, not the attorney/client 23 privilege. Do you have something else maybe? 24 MR. O'BOYLE: Maybe I'm talking to my 25 attorney. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 174 1 MR. HOCHMAN: I know that's not your 2 attorney. 3 MR. O'BOYLE: Really? 4 MR. HOCHMAN: Yes. 5 MR. O'BOYLE: William -- 6 THE WITNESS: That is his attorney. 7 MR. O'BOYLE: William, is he there. 8 THE COURT REPORTER: I'm going to go off the 9 record. 10 (Thereupon; an off the record discussion was 11 held; after which the following proceedings were 12 had:) 13 MR. O'BOYLE: Does anybody have a hard copy 14 of the second amended compliant? 15 MR. HOCHMAN: You have it. 16 MR. O'BOYLE: A clean copy, does anyone have 17 it? 18 MR. GOLDSTEIN: I don't believe I do. 19 THE WITNESS: I don't. 20 MR. O'BOYLE: No. Can you mark this. 21 (Thereupon, Plaintiff's Exhibit 1 was marked 22 for Identification.) 23 MR. HOCHMAN: Has this been marked for 24 today's deposition? 25 THE COURT REPORTER: Yes. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 175 MR. O'BOYLE: Don't need it. It's for the witness. MR. HOCHMAN: It's for the witness? MR. GOLDSTEIN: Let me take a look at it. MR. O'BOYLE: Are we ready, madam? THE COURT REPORTER: We're ready. (Thereupon, the conclusion of the deposition was resumed in Volume II.) Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. 9:14-CV-81250-KAM MARTIN E. O'BOYLE, Plaintiff, Vs. ROBERT A. SWEETAPPLE and MAYOR SCOTT MORGAN, Defendants. DEPOSITION OF ROBERT SWEETAPPLE Taken on behalf of the Plaintiff VOLUME II PAGES 176 - 283 DATE TAKEN: Friday, May 27, 2016 TIME: 9:00 a.m. - 7:00 p.m. PLACE: THE OFFICE OF DAUGHTERS REPORTING 1515 North Federal Highway Suite 300 Boca Raton, Florida 33432 Examination of the witness taken before: LISA GREENWELL, Merit Reporter DAUGHTERS REPORTING, INC. 934 North University Drive Suite 224 Coral Springs, Florida 33071 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 176 1 2 3 4 5 6 7 8 9 10 11 Elra 13 14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCE FOR THE PLAINTIFF MARTIN E. O'BOYLE, pro se 1280 West Newport Center Drive Deerfield Beach, Florida 33442 APPEARANCE FOR THE DEFENDANT ROBERT A. SWEETAPPLE JOSHUA A. GOLDSTEIN, Esquire THE LAW OFFICES OF COLE, SCOTT & KISSANE, P.A. 1645 Palm Beach Lakes Boulevard Second Floor West Palm Beach, Florida 33401 APPEARANCE FOR THE DEFENDANT Town of Gulf Stream JEFFREY L. HOCHMAN, Esquire THE LAW OFFICES OF JOHNSON, ANSELMO, MURDOCH, BURKE PIPER & HOCHMAN, P.A. 2455 East Sunrise Boulevard Suite 1000 Fort Lauderdale, Florida 33304 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 177 178 1 I -N -D -E -X 2 3 DEPOSITION OF ROBERT A. SWEETAPPLE Page No. 4 5 Continuing 6 Direct Examination by Mr. O'Boyle 179 7 8 9 10 11 12 13 E -X -H -I -B -I -T -S 14 Plaintiff Page 15 No. 2 bill 260 16 17 18 19 CERTIFIED QUESTIONS 20 Page Line 21 200 25 22 209 9 23 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 179 1 (Thereupon, the following proceedings were had:) 2 BY MR. O'BOYLE: 3 Q. Mr. Sweetapple, what the court reporter give you 4 a moment ago is the second amended complaint in the 5 matter of Martin O'Boyle vs. Robert Sweetapple and Town 6 of Gulf Stream. 7 May I ask how that's marked, please? 8 THE COURT REPORTER: Plaintiff's 1. 9 BY MR. O'BOYLE: 10 Q. Mr. Sweetapple, for the sake of privity, I hope, 11 I'd like for you to go through, there are 70 paragraphs 12 in here, and tell me which ones are true, which ones are 13 false, which ones are partially true, which ones are 14 partially false and which ones you don't know? 15 A. Okay. 16 MR. GOLDSTEIN: I'm going to object to the 17 form of this question. It's an improper question 18 to ask. 19 THE WITNESS: Let me read this. 20 MR. O'BOYLE: Sure. Take your time. 21 MR. GOLDSTEIN: Moreover, I set forth that 22 any position with respect to the allegations that 23 the Plaintiff would have been set forth in our 24 answer. I suspect you have a copy of our answer? 25 THE WITNESS: There's notes on this, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 W-2 1 Mr. O'Boyle. Do you want -- it says discuss 2 settlement. Do you want me to read that or do 3 you want to give me a copy that has no notes on 4 it? 5 BY MR. O'BOYLE: 6 Q. How about if we do this, just -- 7 MR. HOCHMAN: Do you waive the privilege? 8 MR. O'BOYLE: Have I waived the privilege? 9 I'm a laymen. 10 MR. HOCHMAN: Exactly my point, Mr. O'Boyle. 11 Thank you. Finally you got caught up in it. I 12 love it. 13 MR. O'BOYLE: I got caught up in it. 14 MR. HOCHMAN: Yes, you agree that you're not 15 a lawyer. 16 MR. O'BOYLE: I don't think I ever 17 represented that I -- 18 MR. HOCHMAN: You asserted privilege before. 19 MR. O'BOYLE: I'm allowed to assert a 20 privilege, lawyer or no lawyer. 21 MR. HOCHMAN: Okay. 22 THE WITNESS: Do you want to substitute this 23 for a clean copy? 24 MR. O'BOYLE: I do. And if I could -- give 25 me a moment. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 181 1 THE WITNESS: I'll see if I can get this 2 decal off of here. 3 MR. HOCHMAN: May I see the document, 4 please, Mr. Sweetapple. 5 THE WITNESS: Sure. 6 MR. HOCHMAN: Before you rip the decal off, 7 it is marked as an exhibit. Just want to see 8 what we're doing here. 9 MR. O'BOYLE: Do you have the other Second 10 Amendment. 11 MS. BAEZ: You gave it to John. 12 MR. HOCHMAN: Actually, it's only this page, 13 Page 3. It's just discussed settlement which he 14 did. I don't believe there's an issue. It's all 15 up to you now. 16 MR. O'BOYLE: This is Mr. Sweetapple? 17 MR. HOCHMAN: Yeah, this is the one that's 18 marked. 19 MR. O'BOYLE: Yeah. 20 MR. HOCHMAN: Okay. We'll use that one. 21 THE WITNESS: Use the one with the 22 handwriting on it? 23 MR. HOCHMAN: Yes. 24 THE WITNESS: Okay. 25 MR. HOCHMAN: Mr. O'Boyle, do you want me to Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 MGM 1 see if I can get in contact with the witness, see 2 if I can have her show up even without a subpoena 3 or do you want to finish up with this deposition? 4 MR. O'BOYLE: Well, we're going to be for 5 beyond 4:30 at this point. 6 MR. HOCHMAN: So, tell me what you'd like me 7 to do? 8 MR. O'BOYLE: If she'll come, that would be 9 great. If you'll call her, sure. 10 MR. HOCHMAN: I will try to call her. My 11 question is, it seems odd, though, I am not going 12 to tell her to come if Mr. Sweetapple's 13 deposition is not going to be concluded. 14 MR. O'BOYLE: Well, I think once we find 15 that out, we're going to have to make that 16 decision. 17 MR. HOCHMAN: Well, I don't want to bother 18 her with a phone call to say I'll let you know. 19 I want to -- if you're saying -- 20 MR. O'BOYLE: Let's just get done because 21 we're -- 22 MR. HOCHMAN: Well -- but here's the point, 23 you wanted to stay on schedule at 4:30 was my 24 understanding. 25 MR. O'BOYLE: Yeah, but let's not worry Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 ME 1 about it right now. 2 MR. HOCHMAN: But I'm saying, if you want 3 her to be here at 4:30 I have to call her now, 4 it's 4:00 o'clock. 5 MR. O'BOYLE: I understand. 6 MR. HOCHMAN: So, just give me an 7 instruction, the instruction is either A, please 8 try to call her, have her get here at 4:30 and if 9 she shows up, Mr. Sweetapple is done or don't 10 worry about it. 11 MR. O'BOYLE: Let me use my words, I think 12 they're going to be the same. If she shows up, 13 she shows up. She knows she's supposed to as I 14 understand it. 15 MR. HOCHMAN: I don't believe she does 16 because she's not under subpoena. 17 MR. O'BOYLE: I understand. If she's 18 supposed to show up. If she doesn't show up, she 19 doesn't show up. If she does show up, we can't 20 have two depositions at once unless I try new 21 things which I have no intent on doing. 22 So, let's go on with the deposition of 23 Mr. Sweetapple. 24 MR. HOCHMAN: Okay. Just because of that, I 25 am not then going to contact the witness in an Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 effort to get her here, even though she doesn't 2 have a subpoena, do we agree? 3 MR. O'BOYLE: No, because I don't know 4 whether she doesn't -- I don't know any of that. 5 But let's go on with Mr. Sweetapple. 6 THE WITNESS: Okay. Can I start reading 7 this again because -- 8 MR. O'BOYLE: Please. 9 THE WITNESS: -- little disruptive putting 10 it mildly. 11 MR. O'BOYLE: Please, please, I apologize. 12 MR. HOCHMAN: I can't see it any way. And 13 whatever you have written down won't have any 14 impact on what I do in this case because I may 15 have things that help you. You're not going to 16 help me. 17 MR. O'B0YLE: Boy, is that an insult or 18 what. 19 MR. HOCHMAN: No, it's just how I would 20 litigate. It's not about you personally. 21 THE WITNESS: It really is hard to read, I'm 22 sorry. He wants to ask me about each sentence, I 23 want to give him my best answer. You guys -- 24 MR. HOCHMAN: Did the man bun comment ran 25 you off? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 185 1 THE WITNESS: Yeah, man bun, everybody 2 laughing. I read in quiet usually. This is a 3 legal pleading, it's not like reading, you know, 4 the comics. 5 BY MR. O'BOYLE: 6 Q. Mr. Sweetapple, please don't let your counsel -- 7 A. Okay. 8 Q. Thank you. 9 A. You want me to stop at Count I, which is me, or 10 you want me to go on to Count II? 11 Q. I'd like you to go through all 70, but if you 12 want to do it a piece at a time, that's fine with me. 13 A. No, I'll go through the whole thing. I thought 14 you were just going to ask me about this one. 15 Okay. Do you want me to start with the 16 sentencing one -by -one. 17 Q. Yeah, the paragraphs one -by -one. 18 A. And you want to know, let me write it down, true, 19 false, just like I'm doing an answer; true, false? 20 Q. True, false, partially true, partially false. 21 A. Just respond to it as I think is appropriate? 22 Q. Yeah, or you don't know. 23 MR. GOLDSTEIN: I'm going to object -- 24 THE WITNESS: If there's an objection, if 25 there's a legal conclusion or something, it goes Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 into lawyer/client. 2 BY MR. O'BOYLE: 3 Q. You're here -- 4 A. So, Plaintiff, Martin E. O'Boyle -- Second 5 Amended Complaint. Plaintiff, Martin E. O'Boyle, 6 Plaintiff, sues Defendants, Robert A. Sweetapple 7 ("Sweetapple") and the Town of Gulf Stream ("Town") and 8 alleges as follows: Parties, jurisdiction, and venue. 9 Q. Let me stop you there, Mr. Sweetapple. It would 10 probably be easier if we started at Paragraph 7 rather 11 than the introductory. 12 A. Okay, that's fine. The Defendant, Town of Gulf 13 Stream, "Town", is a municipal corporation of the State 14 of Florida seated in the Southern District of Florida. 15 I don't have any personal knowledge of that, but 16 I presume that's true. 17 Q. One second. Okay. 18 A. Background, Plaintiff's history of First 19 Amendment activities with Town. 20 Q. Where are you, Paragraph 8 is next? 21 A. Well, there's two sevens, there's two sevens -- 22 you've got seven and background and then you have 23 another background. 24 Q. I'm sorry, under background is where I was asking 25 you to start. I didn't see the first seven. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 A. Okay. Well, I responded to the first seven, I'm 2 on the second seven. 3 Q. Okay. That's fine. 4 A. So, we're at the same place. 5 Q. Okay. 6 A. So, Plaintiff's history of First Amendment 7 activities with the Town. Paragraph -- second seven, 8 the Town is a relatively small municipality with 9 approximately a thousand residents located within its an 10 approximately five hundred acres of land. 11 My opinion is, it is a small municipality. I 12 have no idea how many residents live there. And I have 13 no idea what the geographic area of the Town is. 14 Q. Wait one second. You have to have some idea of 15 the number of residents? Example, you know it's not 16 hundred thousand? 17 MR. GOLDSTEIN: Object to the form. 18 THE WITNESS: Yeah. I mean, I've seen 19 somewhere a statement of the number of residents. 20 I didn't focus if it's five thousand, one 21 thousand, five hundred, seven -fifty. 22 I don't know residents you mean people that 23 are domiciled there, people come down for the 24 season. I have no idea if there's a thousand 25 residents, but, you know -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 BY MR. O'BOYLE: 2 Q. Okay. 3 A. I'm just trying to be as candid with you as I can 4 be. 5 Q. Okay. I appreciate it. 6 A. And I'll do that with all the sentences I can. 7 Q. Okay. 8 A. Okay. So, eight is, Plaintiff is a resident of 9 the Town owning and occupying the home located at 10 23 North Hidden Harbor Drive, Gulf Stream, Florida, 11 33483. 12 I believe you live in the Town. I don't know, as 13 far as, resident, if you're a voter there. I have no 14 knowledge in that regard. I know you have another -- 15 another home or homes or I've seen that somewhere. 16 I recognize that address from the documents I've 17 seen. I presume that you own it. I've never looked at 18 the title to see if it's in your name or not. 19 And it says you are occupying it and I presume 20 you're occupying it, but I have no personal knowledge of 21 any of those things. 22 Q. Not even the address? 23 A. Well, I've seen the address as being related to 24 you, but I don't know if you own it, occupy it, if 25 you're a resident. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 ME 1 Q. Gotcha. 2 A. As I understood from what I read, it was -- it 3 was under construction or it had been demolished or had 4 some damage from a hurricane and you were -- I remember 5 there was some issues with a Jiffy John in the front or 6 some kind of problems, I forget what it was. I don't 7 know if you're living there now, but -- 8 Q. Well -- 9 A. What I read it was with regards to issues 10 concerning damage and code issues and something I read. 11 Q. I understand. I just -- 12 A. Okay. So -- 13 Q. I don't like to use bathrooms, I try to go out 14 and use the Jiffy Johns. 15 A. No, I was referring to it was under construction 16 and you were remodeling it or something. That's -- 17 don't know if you're living there now or not, or how 18 long ago that was. 19 Q. Thank you. 20 A. Okay. Nine, Plaintiff is an avid supporter of 21 Florida Public Record Law and, in an exercise of his 22 constitutional and statutory rights, has over the years 23 submitted numerous public records requests in the Town 24 and various other municipal agencies. 25 I don't know if you're an avid supporter of Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 1 public -- Florida's Public Records Law. I've never had 2 any conversations with you, so I don't know who you 3 support or what you support. 4 I don't know if you're exercising your 5 constitutional and statutory rights. 6 And from what I have read, you have, over the 7 years, submitted, from what I can see, several thousand 8 public records requests to -- of what I'm aware of, is 9 the Town, the State Attorney, the Town of Long Port. 10 I don't know that I'm aware of any other 11 municipalities or agencies as I sit here. 12 Q. Where is that, I'm missing -- 13 A. Number nine. 14 Q. When you say "thousands"? 15 A. I said you asked me -- you have submitted 16 numerous, I said I know that you've submitted -- I call 17 thousands numerous. 18 Q. I see. 19 A. I don't know what you call numerous. 20 Q. What would you call -- 21 A. I don't call a hundred numerous. 22 Q. What do you call fifty thousand? 23 A. Numerous. 24 Q. One thousand numerous, fifty thousand numerous? 25 A. Well, I'm just trying to just tell you how I read Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 191 1 numerous. So, I'm saying, I think what you said here 2 about numerous is true because of the numbers I'm 3 familiar with -- 4 Q. Okay. So, let's go back over it. 5 A. -- from what I read. 6 Q. The Florida Public Records Law, does that have 7 anything to do with New Jersey? 8 A. But it says in an exercise of his constitutional 9 and statutory rights has over the years submitted 10 numerous public records requests to the Town and various 11 other municipalities and agencies. 12 So, I took that to mean -- I'm telling you what I 13 know about. So, I know about New Jersey, the State 14 Attorney and Gulf Stream. 15 Q. Tell me -- 16 A. I take that back. I think I know -- I am not 17 sure it was you personally, but I -- something about 18 Delray. 19 Q. Tell me -- 20 A. Talking about you personally, right? Just in 21 your name? 22 Q. Tell me what you know about Long Port, 23 New Jersey? 24 A. That's my work product. I know a lot about 25 Long Port because I've done a lot of investigation about Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 192 1 Long Port as part of my representation of the Town. 2 Q. I see. You agree with me, do you not, that New 3 Jersey, a Florida Public Records Law, is not a law that 4 is enforceable or even existing in the State of New 5 Jersey, do you agree with that? 6 MR. GOLDSTEIN: Object to the form. 7 THE WITNESS: That's a legal opinion. 8 BY MR. O'BOYLE: 9 Q. But give me your laymen's opinion? 10 MR. GOLDSTEIN: Form. 11 THE WITNESS: I'll try if I understand. 12 You're saying that if somebody in New Jersey -- 13 if there was a violation of the Florida Records 14 Law in Florida, can somebody sued in New Jersey 15 for that? 16 BY MR. O'BOYLE: 17 Q. No, that's not what I asked at all. What you 18 said was that the numerous public records requests were 19 submitted to, I think you said the State Attorney, the 20 Town of Gulf Stream and the State of Law Enforcement -- 21 Long Port which is, of course, the State of New Jersey. 22 What I asked you was, how does the Florida Public 23 Records Law fit into records requests in the State of 24 New Jersey? 25 MR. GOLDSTEIN: Asked and answered. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 193 1 THE WITNESS: When I read this, I see the 2 reference the Florida Public Records Law. But 3 then it goes on and it seems to expand and it 4 says, in the exercise of his constitution and 5 statutory rights. 6 I look at constitution as being federal, as 7 well as, any state rights. And I look at 8 statutory rights as not just being a Florida 9 statutory rights, I'm looking at all your rights 10 when read it because seems to me that you're 11 being expansive and that's the way I read -- when 12 there's an indication of rights, it would be 13 evert conceivable right related. 14 And then it says, has over the years, so in 15 my mind, I went back to Long Port in the past. 16 And then when he see submitted numerous public 17 records requests to the Town and various other 18 municipalities and agencies, I say that part is 19 true because I know you have submitted numerous 20 public records requests to Gulf Stream, the State 21 Attorney of the 15th Judicial Circuit and Long 22 Port, New Jersey. That's the way I read it. 23 BY MR. O'BOYLE: 24 Q. What would make you say that I submitted, I don't 25 know how many you said, to the 15th Judicial Circuit, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 194 1 that's what you said? 2 A. The reports I read -- Well, I am not going to 3 give you my work product. 4 Q. I don't want your work product. 5 A. The only way I could answer that, Mr. O'Boyle, 6 would be to give you my work product. 7 Q. Well, it's a matter of public record, isn't it, 8 whether someone submits a public records requests? 9 Isn't that open to him and her and her and him? 10 A. You can go find out that way, yes. 11 Q. And did you find out another way? 12 A. I am not going to disclose my work product. 13 Q. I don't want you to disclose your work product. 14 Did you find out another way? 15 A. I can't answer that question without disclosing 16 my work product. 17 Q. I am not asking you to disclose your work 18 product. 19 A. Okay, then, I can't answer your question. 20 Q. Okay, that's fine. Let's go back over it. 21 A. Okay. So, let's go to -- 22 Q. Florida Public Records Law, to your knowledge, is 23 that the law that enforces the Records Act which happens 24 to be called OPRAH, in New Jersey? 25 A. Does the Florida Public Records Act enforce the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 195 1 New Jersey Open Public Records Act? 2 Q. No. The Florida Public Records of Law, is 3 that -- could someone -- Let me ask you this way, could 4 someone go to New Jersey and file a request for a public 5 record under -- it's called OPRAH up there, and if they 6 don't get it, sue them under the Florida Public Records 7 Law? 8 A. Well, first of all I don't practice law in New 9 Jersey, I'm not licensed in New Jersey, so I am not 10 going to give you any opinions about OPRAH. 11 But my -- and you're asking me for a legal 12 opinion, but I'll give you a lay opinion which is, I 13 don't think you could sue for the violation of a Florida 14 public records request for something that happened in 15 New Jersey. 16 Q. Just so I'm clear, what you said -- and I am not 17 trying to put words in your mouth -- 18 MR. GOLDSTEIN: Object. 19 BY MR. O'BOYLE: 20 Q. -- you can't utilize the Florida Public Records 21 Law to sue the State of New Jersey or any of its body 22 politics if they don't produce the records under OPRAH? 23 MR. GOLDSTEIN: Object to the form. 24 THE WITNESS: Well, I don't -- I don't -- I 25 don't profess to have any knowledge of OPRAH or Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 W. 1 New Jersey law. 2 And I'm not going to give you a legal 3 opinion about the Florida Act. From a lay 4 person, I told you, I don't know how -- from a 5 lay view, it wouldn't seem to me that the OPRAH 6 Law would have any provision that applied a 7 Florida violation to it. Nothing would preclude 8 that. 9 The State Legislature could, on principals 10 of comedy, for instance, permit that. But I 11 haven't cited OPRAH and I am not licensed in New 12 Jersey to opine on that. I'm just trying to give 13 you my reaction to your allegation which is what 14 you asked me to do. 15 BY MR. O'BOYLE: 16 Q. Right. And I'm trying to understand -- 17 A. Okay. Well, try again because I'm sorry, I may 18 be misunderstanding something. 19 Q. You said, Plaintiff is an avid supporter of 20 Florida's Public Records Law, what factual evidence do 21 you have? 22 A. No, I said you said Plaintiff is an avid 23 supporter of Florida's Public Records Law. I don't know 24 if you're a supporter or a detractor. 25 Q. Okay. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 197 1 A. I don't know what your personal goals are. I 2 don't know what your personal ambitions are. 3 From a personal standpoint, I have work product 4 and I have legal conclusions that would cause me to have 5 my own opinion. 6 So, I've never spoken to you about whether you're 7 an avid supporter of Florida's Public Records Law. 8 Anybody who's an avid supporter of Florida Public 9 Records Law, in my mind, would not have the reaction 10 about his conduct at the Florida Legislature has 11 publicly made about your conduct. 12 Q. And what is that? 13 A. From what I read from reports of committees, 14 there was numerous statements of outrage and concern 15 over your activities in the public record. 16 Q. And they mentioned specifically Martin O'Boyle? 17 A. They mentioned specifically the activities that 18 you're engaged in in Gulf Stream, Florida and I can't 19 remember if they actually say your name. 20 Q. Okay. 21 A. So, I don't know if you're an avid supporter or 22 avid detractor. I don't know what your motivation is 23 for filing dozens and dozens of requests on the same 24 day. 25 And then when Mr. O'Hare comes in and does sixty Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 the next day, I don't know if you're doing it because 2 you're an avid supporter. 3 Q. Okay. Do you have a trailer, a big busted up 4 silver trailer in Deerfield Beach? 5 A. No. 6 Q. On the beach? 7 A. No. 8 MR. GOLDSTEIN: Object to form. 9 BY MR. O'BOYLE: 10 Q. Did you take one away? 11 A. No. 12 Q. Okay. Does an entity in which you're involved in 13 have a big busted up trailer, one of those silver 14 Airstreams on the beach in Deerfield Beach or in the 15 Deerfield Beach area just north of Hillsboro? 16 A. There's no -- the entity you're referring to, 17 Deerfield Beach, Inc., does not have a trailer on the 18 beach. 19 Q. Do you have one? 20 A. No. 21 Q. Okay. Was there one there? 22 A. Was there one there? 23 Q. Yes. 24 A. Yes. 25 Q. Okay. What happened to it? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 199 1 A. It has been removed. 2 Q. Okay. Were there signs surrounding it saying, 3 you can't cross the beach -- I'm sorry, the sand? 4 In other words, if I was coming from the south, 5 I'd have to stop and turn around. And if I was coming 6 from the north, I'd have to stop and turn around. Were 7 there signs like that sort of surrounding your trailer? 8 MR. GOLDSTEIN: Object to the form. 9 THE WITNESS: The property had signs, I 10 think, that said private property, no 11 trespassing, but the public had a right to cross 12 to get to the high water mark and crossed 13 regularly. 14 BY MR. O'BOYLE: 15 Q. Is that what the sign said or did the sign say -- 16 A. The sign said what they said. 17 Q. I know. Did the signs have the sheriff's emblem 18 and say, you will be arrested if you cross the -- 19 A. I'd have to look at the sign. I don't think it 20 said you will be arrested if you crossed the sand. 21 Q. Is it possible it said that? 22 A. Anything's possible. I'd have to see the sign. 23 I haven't seen the sign for some time. 24 Q. How many records requests did you make in 25 connection with that? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 200 1 A. You mean, requests with the litigation of 2 Deerfield? 3 Q. Okay. 4 A. Town of Deerfield? 5 Q. Okay. 6 A. Two or three on behalf of Deerfield Beach, Inc., 7 I believe. 8 Q. And how about in total with Deerfield? 9 A. That's the only matter, I think, there were any 10 requests made. 11 Q. And how many in total with Deerfield? 12 A. I'm speculating, but I'd say two or three, best I 13 recall. 14 Q. Okay. Who's Laura Watson? 15 A. Laura Watson is a former Circuit Court Judge in 16 the 17th Judicial Circuit. 17 Q. And when you said "former", she retired? 18 A. No, she was removed by the Florida Supreme Court. 19 Q. And who represented her? 20 A. I was one of her attorneys. 21 Q. Okay. Who was her lead attorney? 22 A. I believe I would be considered lead with 23 Jay Spechler. I'd say I would be considered a lead 24 attorney, at least. 25 Q. And Jay Spechler, is he the one who owned the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 201 1 trailer a long with you? 2 A. I am not going to go into the ownership of a 3 company that I represent and that I am affiliated with. 4 That's private, confidential business information of 5 Mr. Spechler's, so I can't do that. 6 MR. O'BOYLE: Would you certify that, young 7 lady. 8 MR. HOCHMAN: I also -- 9 THE WITNESS: You want me to keep going with 10 the document? You diverted to Deerfield. 11 MR. O'BOYLE: Yeah, I want to keep going, 12 but I'm allowed -- 13 THE WITNESS: You can do what you want, I 14 just wanted to know if I should get back to what 15 I was doing or not. 16 MR. O'BOYLE: We'll figure it out. 17 THE WITNESS: I'll follow your lead, 18 Mr. O'Boyle. 19 MR. HOCHMAN: I'm going to ask the court 20 reporter for another excerpt starting with this 21 discussion about the trailer and the beach and 22 ending with my request for another excerpt, 23 please. 24 BY MR. O'BOYLE: 25 Q. How many records requests did you make with Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 202 1 Ms. Watson or any issues surrounding Ms. Watson? 2 MR. GOLDSTEIN: Object to the form. 3 THE WITNESS: My best recollection would be 4 one. 5 BY MR. O'BOYLE: 6 Q. And would that include the other lawyers in 7 addition to you who represented her? 8 A. I couldn't speak for the other lawyers. I don't 9 have any recollection of theirs. I know that I filed 10 one, I believe. I believe I filed it with the Judicial 11 Qualifications Commission. 12 Q. Did Mr. Spechler -- Spechler was a former judge? 13 A. He was a judge for twenty some years, right. 14 Q. And he was ousted, correct? 15 A. No. 16 Q. Judge Tobin did not denounce him? 17 A. No. 18 Q. What happened between him and Judge Tobin? 19 A. Well, that's confidential. I represented 20 Judge Spechler as well. 21 Q. I see. Okay, that's fine. 22 Okay. In New Jersey, do you have any reason to 23 believe that making public records is a constitutional 24 right? 25 A. I can give you a lay opinion and I -- I don't Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 203 1 know as a lay person because I've never read the New 2 Jersey Constitution. I've never read OPRAH. I don't 3 know if it's a constitutional right. I don't know if 4 it's a statutory right. I don't know if it's a Rule of 5 Civil Procedure. I haven't compared it to Florida Law. 6 So, I'm only giving you a lay opinion because I'm 7 not a lawyer in New Jersey. 8 Q. So, your answer is you don't know? 9 A. I don't know. 10 Q. Okay. Thank you. 11 Then we go on and said, has over the years 12 submitted numerous public records requests to the Town 13 and various other municipalities and agencies. 14 What does numerous mean? 15 MR. GOLDSTEIN: Asked and answered. 16 THE WITNESS: Numerous, to me, in this 17 context meant like, I guess in my mind, more than 18 a hundred. Just like when I read various, I 19 thought it meant three or more which is why I 20 said I thought it was true because I had three in 21 my mind. 22 So, numerous meant to me over a hundred and 23 various meant there were three and I counted 24 three. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 204 1 BY MR. O'BOYLE: 2 Q. Okay. 3 A. So, I said, I think I understand what you're 4 saying. 5 Q. Okay. So, numerous as it's written here, you 6 think it means over a hundred? 7 A. First thing that came to my mind is I said that's 8 true because numerous, yeah, that to me is numerous. 9 Q. Okay. That would be over a hundred? 10 A. I knew there were thousands, so I said, sure, 11 it's over a hundred, that's numerous. 12 Q. Well, now you do said I knew. You didn't say I 13 heard or I thought, you said I knew there were 14 thousands. 15 A. Okay. I should say I read, I had information and 16 I concluded, but I did not count. 17 Q. Okay. Now, when you said "you read", were you 18 reading the National Enquirer? 19 MR. GOLDSTEIN: Object to the form. 20 THE WITNESS: I'm not going to disclose my 21 work product. 22 BY MR. O'BOYLE: 23 Q. Telling a -- what newspaper you're reading is 24 work product? 25 A. I didn't say I read a newspaper, you said that, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 205 1 Mr. O'Boyle. 2 MR. O'BOYLE: Can you read Mr. Sweetapple's 3 answer? I think it was one or two questions back 4 and I think you used the term newspapers. 5 THE COURT REPORTER: You used the word 6 newspapers. I'm all the way back to Judge Tobin 7 and Spechler and there's no word newspaper. 8 BY MR. O'BOYLE: 9 Q. Okay. How many, to your knowledge, records 10 requests did I submit to the Town? 11 A. What time period? I shouldn't even ask you 12 because I wouldn't answer that without having the tally 13 in front of me because I couldn't, in my mind, isolate 14 it per month or take you from March to March. 15 Q. Okay. So, where it says, over the years 16 submitted numerous public records requests of the Town 17 and various other municipalities, you don't know what 18 that means? 19 MR. GOLDSTEIN: Object to the form. 20 THE WITNESS: I know what it means to me. I 21 think I've told you. To me, it meant that you 22 had submitted, at least, a hundred and that 23 seemed true, was true from everything I had seen. 24 And it meant that there were, at least, 25 three municipalities or agencies. And that, I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 12 1 believe, is true from what you've read and seen. 2 BY MR. O'BOYLE: 3 Q. So, there were three agencies and a hundred 4 records requests, did I get that right? 5 MR. GOLDSTEIN: Object to the form. 6 THE WITNESS: No. 7 BY MR. O'BOYLE: 6 Q. Could you help me out? 9 A. I said when I -- when I read this and -- when you 10 said numerous, you don't put a number. So, in my mind I 11 said -- without even thinking about it, I said more than 12 a hundred. To me, that's what numerous meant. 13 I said, I know that there's more than that. That 14 seems numerous to me. So, since there are thousands, 15 numerous would be certainly met. 16 And then when I saw various other municipalities 17 and agencies, various has to be three or more. And I 18 could think of three, so I said that's true. 19 So, you're asking me what I believe just sitting 20 here reading this is true, false, somewhat true, I'm 21 going through each phrase and trying to do that. 22 Want to move to the next one? 23 Q. Hold on. Is hundred, in your opinion, acceptable 24 to a Town like Gulf Stream? 25 A. I don't have an opinion as to acceptable or Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 207 1 unacceptable. 2 Q. Okay. Is a hundred, in your opinion, is that 3 excessive? 4 A. I'm not going to give you my legal opinion. 5 Q. I don't want it. 6 A. And you asked me if I thought this statement in 7 Paragraph 9 was true with regard to submitting numerous 8 public records requests and I've answered that. 9 I'm not going to give you my opinion as to 10 quantitative issues or legal issues. 11 Q. Give me your lay opinion, if you will? 12 A. As to what? 13 Q. As to whether a hundred is excessive? 14 MR. GOLDSTEIN: Form. 15 BY MR. O'BOYLE: 16 Q. I'm not a lawyer and I have my opinion as to 17 what -- 18 A. Well, I'm not going to give you -- I don't have 19 an opinion on that, so I don't have enough facts. I 20 don't know is it being done to target a Town so that -- 21 by requests by an entity that isn't real to intimidate 22 them to do what you want as Mr. Chandler was describing 23 with the hundred requests from Cafi with the Commerce 24 Group. You want me to tell you whether you think that's 25 inappropriate? That's a legal conclusion, so I am not Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 going to give you that. 2 Q. And that's fine. But again, you could give me a 3 laymen's opinion as opposed to a legal opinion? 4 MR. GOLDSTEIN: Asked and answered. 5 THE WITNESS: What's that? 6 BY MR. O'BOYLE: 7 Q. I said, you can give me a laymen's opinion? 8 A. I can't. 9 Q. You can't? 10 A. No. 11 MR. GOLDSTEIN: Asked and answered. 12 BY MR. O'BOYLE: 13 Q. Okay. 14 A. I haven't thought of records requests as a laymen 15 ever. 16 Q. Okay. Are you familiar with the most recent 17 Supreme Court decision in records? 18 A. Justice Pariente's decision regarding attorney's 19 fees? 20 Q. I think it went beyond attorney's fees. 21 A. Yes, I've read that opinion. 22 Q. Okay. So, doesn't that opinion make a difference 23 whether you were well intended, bad intended, harassing, 24 doesn't make any difference at all in the scheme of 25 making public records? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 209 1 MR. GOLDSTEIN: Object to form. 2 THE WITNESS: Opinion speaks for itself. I 3 am not going to give you my legal analysis of the 4 opinion. You have your own lawyers. 5 BY MR. O'BOYLE: 6 Q. Okay. 7 A. You will argue what you believe the opinion says 8 and we'll argue what we believe the opinion says. 9 Q. From a laymen's point of view, if someone told 10 you that someone submitted ten thousands requests at 11 Gulf Stream, to Gulf Stream, how would you react to 12 that? 13 A. I don't know. I would be speculating. If I -- 14 it's impossible for me to give you an opinion as if I 15 were a laymen looking at this because my mind is totally 16 implicated with what I know as a lawyer and what I know 17 from all my work product. 18 So, I can't tell you -- if I didn't know all the 19 information I have, how I would think about this as just 20 a lay person. But I imagine, I can speculate, but 21 that's all I can do. 22 MR. O'BOYLE: Madam reporter, would you 23 kindly certify that, please. 24 BY MR. O'BOYLE: 25 Q. We can now go on to the next one. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 210 1 A. Paragraph 10? 2 Q. Yes. 3 A. Ten, occasionally Plaintiff's public records 4 requests are not complied with and Plaintiff has his -- 5 has exercised his right under Florida Statute 119 to 6 bring a lawsuit to enforce his rights under the public 7 records laws. 8 Whether or not your public records requests are 9 complied with is a legal conclusion and legal opinion 10 which I will not provide and cannot provide to you. 11 I don't have any -- I've never seen any ruling 12 where that legal conclusion has been established. 13 And then it says, and Plaintiff has exercised his 14 rights under Florida Statute to bring a lawsuit to 15 enforce his rights under the public records law. 16 I am aware that you have brought numerous 17 lawsuits to enforce your rights under the public records 18 law. 19 Q. Now, unless I heard wrong, Paragraph 10, the 20 words are "are not". I thought you said "are"? 21 A. No, are not complied with. You said are not 22 complied with. Maybe I spoke too quickly. 23 Q. Okay. So, occasionally Plaintiff's public 24 records requests are not complied with, okay. 25 Eleven. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 211 1 A. Eleven, Plaintiff has filed approximately 2 twenty-nine lawsuits against the Town for alleged 3 violations of the public records law. 4 I don't know if that's the amount. As of the 5 date of this lawsuit -- is the date of this lawsuit the 6 date on the top, 6/19/2015? 7 It says the date of the lawsuit, is that the date a the lawsuit was filed or the date the second amended 9 complaint was filed. 10 Q. It looks like the date of the Second Amended 11 Complaint. 12 A. So, in July or June of last year, as of the date 13 of this lawsuit, Plaintiff is currently engaged in 14 twelve lawsuits against the Town related to alleged 15 violations of the -- I believe that's close. As of June 16 of last year, I think that you had approximately, 17 twelve cases pending. 18 Plaintiff has also filed one lawsuit for 19 violation of 2680114 Florida Stat because he was not 20 allowed to speak before the Town for a parking ordinance 21 in response to the Plaintiff's parking his truck at Town 22 Hall, a truck which contained politically charged 23 banners critical to the mayor. 24 I have never reviewed that lawsuit. I have heard 25 that deposition testimony of you and someone else about Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 212 1 it. I don't have any firsthand knowledge of the Town 2 passing a parking ordinance. All I know is 3 lawyer/client communication on that subject. 4 I don't know if the truck contained politically 5 charged banners critical to the mayor. I remember 6 seeing a picture of a truck at some point somewhere and 7 I don't remember even what it said. 8 Q. Are you familiar, by the way, with the Sunshine 9 Suit? 10 A. The Sunshine Suit. What do you mean by the 11 Sunshine Suit? 12 Q. There's a lawsuit, it's -- I call it the Sunshine 13 Suit, it's a violation, I guess, of the Sunshine Law of 14 which the Defendants are you, Mr. Randolph, 15 Mr. O'Connor -- Ms. O'Connor, I'm sorry, and the Town 16 and you are their counsel. Does that sound right? 17 A. There were a number of questions there. 18 MR. GOLDSTEIN: I'm going to object to any 19 line of questioning or discovery related to other 20 pending legal actions as the Magistrate has 21 already ruled on upon that he will not allow 22 discovery in other pending legal actions. 23 THE WITNESS: There were a number of 124 questions. I think I understand what you're 125 getting at if you will indulge me. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 213 1 MR. O'BOYLE: Sure. 2 THE WITNESS: I believe you're asking me if 3 I'm aware of a lawsuit that you brought a long 4 with another entity against Ms. O'Connor, 5 Mr. Randolph, Mr. Morgan and me in the 15th 6 Judicial Circuit related to allegations of 7 violation of the Sunshine Law and the answer is B yes, if that's your question. 9 BY MR. O'BOYLE: 10 Q. That is. 11 A. Okay. 12 Q. And you are counsel under that -- or in 13 connection with that suit, would that be correct? 14 MR. GOLDSTEIN: Object to the form. 15 THE WITNESS: I am. 16 MR. GOLDSTEIN: Counsel for whom? 17 BY MR. O'BOYLE: 18 Q. Counsel for the Defendants. 19 MR. GOLDSTEIN: Are you asking if he's 20 counsel for all the named Defendants? 21 MR. O'BOYLE: Yes. 22 THE WITNESS: I don't believe so. I need to 23 see my appearance to be sure, but I think 24 I'm -- I think my firm and Mr. -- I believe Josh, 25 your firm is counsel for my -- for me, I'm Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 214 1 personally a Defendant. 2 So, I believe my firm and Mr. Goldstein's 3 firm are counsel for me in that case. It's hard 4 to keep track of you, Mr. O'Boyle. 5 BY MR. O'BOYLE: 6 Q. Okay. 7 A. Are we on the next paragraph? 8 Q. We certainly are. Rolling right a long. 9 A. If I'm not mistaken, that's twelve, okay. 10 Plaintiff, likewise, engages in various forms of 11 constitutionally protected acts, speech, with respect to 12 the Town. For example, in 2013, Plaintiff painted the 13 facade of his Gulf Stream house with various political 14 messages criticizing the Town, its then mayor and its 15 commissioners as a result of the Town denying 16 Plaintiff's request for a building permit. The Town 17 ultimately settled the dispute which made its way to 18 Federal Court issuing an apology to Plaintiff and 19 agreeing to pay him $180,000. 20 All right. So, I know you engage -- you engage 21 in various forms of constitutionally protected acts, 22 speech, with respect to the Town, that's a legal 23 conclusion. 24 In 2013, Plaintiff painted the facade of his Gulf 25 Stream house with various political messages criticizing Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 215 1 the Town, its then mayor and its commissioners. That 2 was before my involvement and I've never seen the facade 3 of your house painted with political messages. 4 I don't know if it was done as a result of the 5 Town denying Plaintiff's request for a building permit. 6 I don't know why you painted this political message on 7 the facade of your house. 8 I did hear you in your deposition say you did it 9 to file or -- I think, to file your First Amendment 10 Rights you said, or to enforce your First Amendment 11 Rights I heard your testimony, but I don't have any 12 personal knowledge as to why you did this. 13 Q. Okay. So, you I do know that the Town ultimately settled the 14 dispute and issued an apology and agreed to pay you a 15 sum of money because I did read a settlement agreement. 16 Q. So, the part that says, which made it's way to 17 Federal Court, that's true, am I correct? 18 A. I don't -- I don't know. I don't remember if -- 19 I remember reading -- 20 Q. It's in the settlement agreement? 21 A. I remember reading the settlement agreement. I 22 don't remember the caption if it had one. 23 Q. Okay. So, you don't know whether the settlement 24 agreement dealt with the Federal Court action? 25 A. I don't recall that. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 216 1 Q. Okay. But you do remember that the settlement 2 agreement, there was issuing -- there was an apology 3 issued? 4 A. My recollection is that was in the agreement. 5 Q. And the 180,000? 6 A. I didn't -- the number doesn't stick out with me. 7 I didn't -- didn't remember a number. 8 Q. There was a number, though? 9 A. There was a number, yeah. I mean, somewhere in 10 my mind when I thought -- I think 170,000, so that's 11 close to what I think I'm remembering having read. 12 Q. Trying to shorten me 10,000? 13 A. No, I don't want to do that to you. 14 Q. Okay. Number 13. 15 A. In February 2014, Plaintiff announced that he 16 would run for a council seat in Gulf Stream and 17 subsequently began campaigning throughout the Town and 18 neighboring municipalities. 19 I had no knowledge in February of 2014 that you 20 announced you would run for a council seat in Gulf 21 Stream. 22 And subsequently began campaigning throughout the 23 Town and neighboring municipalities. 24 Plaintiff placed numerous campaign signs 25 throughout the Town, many of which were conclusively Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 217 1 removed by Gulf Stream agents, officials. The signs 2 were targeted for removal at the request of the Town 3 Manager Thrasher because the signs displayed political 4 content. 5 I don't believe I saw any of your campaign signs 6 in the Town of Gulf Stream. I don't know if your signs 7 were removed by Gulf Stream agents or officials. I 8 don't know if the signs were targeted for removal at the 9 request of Town Manager Thrasher because the signs 10 displayed political content. I have no knowledge of 11 that. 12 Q. That's fine. 13 A. Fourteen, Mr. O'Boyle, 14? 14 Q. Yes, yes. 15 A. During the same time period, Plaintiff engaged in 16 constitutionally protected speech by flying banners and 17 displaying signs that were critical of his opponents or 18 otherwise carried political message. 19 I take that you're referring to February 2014. 20 And I never saw any banners or signs that were critical 21 to your opponents. And I never saw any of your signs in 22 that time that carried political messages. 23 In response, the Town threatened Plaintiff with 24 adverse action, including code enforcement hearings 25 carrying daily fines not to exceed $500 per day or per Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 218 1 sign per day if he did not remove his signs or otherwise 2 cease such political speech. 3 I have no knowledge of any such -- no personal 4 knowledge of any of that. 5 Q. Okay. Give me ten seconds, please? 6 A. Sure. 7 THE COURT REPORTER: Can we take a break. 8 MR. HOCHMAN: Let the record reflect it is 9 now 5:00 o'clock. 10 THE WITNESS: This is when I'm supposed to 11 leave, but I'm going to do my whole seven hours 12 so I satisfy his needs. 13 (Thereupon, a recess was taken; after which 14 the following proceedings were had:) 15 THE WITNESS: How much more time do I have 16 because I want to get to a baccalaureate for my 17 youngest daughter, but I want to give you all the 18 time. 19 MR. O'BOYLE: I don't know. 20 MS. BAEZ: I'll let you know. You guys can 21 go back on the record. 22 THE WITNESS: I'm happy to stay here. 23 MR. GOLDSTEIN: I have an hour left based on 24 my calculation. 25 MS. BAEZ: It's possible just let me check Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 219 1 on it. 2 MR. O'BOYLE: What are you calculating? 3 MS. BAEZ: You guys can go back on. 4 MR. O'BOYLE: I think that's a good idea. 5 Spotlight is on you. 6 I think we're 13. 7 MR. GOLDSTEIN: No, we just finished 13. 8 THE WITNESS: Where were we? 9 MR. GOLDSTEIN: We were in 13 -- 14, I think 10 we were on 14. 11 THE WITNESS: Do you have any questions on 12 13, Mr. O'Boyle. 13 MR. O'BOYLE: No, I do not. I think he's 14 right. 15 MS. BAEZ: I have an hour -and -a -half. 16 MR. HOCHMAN: That's not going to be 17 acceptable to me. 18 MS. BAEZ: I didn't ask. I'm saying, that's 19 what I have. 20 MR. O'BOYLE: That's what the seven hours 21 comes to, right? 22 MS. BAEZ: Yeah. 23 MR. HOCHMAN: I understand the notion of 24 seven hours is an approximate, but I don't think 25 starting at 9:00 and ending after 7:00 o'clock Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 220 1 is appropriate. THE WITNESS: 2 MR. O'BOYLE: Anyway, we're not going to go 3 into that, we're going to go through it and if 4 you want to walk out, you'll walk out. 5 THE WITNESS: Okay. Ready? 6 MR. O'BOYLE: I am. 10 7 THE WITNESS: During this same time period, 8 Plaintiff engaged in constitutionally may be protected 9 speech. I thought we did this by -- yeah, 14. 10 MR. GOLDSTEIN: Yeah, I think we're on 14. 11 THE WITNESS: I said -- I'll do it again if 12 you want. 13 BY MR. O'BOYLE: 14 Q. Just one second. Let me look at it because you 15 may be right. I don't think we did 14. 16 A. Okay. So, during the same time period, Plaintiff 17 engaged in constitutionally protected speech by flying 18 banners and displaying signs that were critical of his 19 opponents or otherwise carried political messages. 20 So, I don't have any personal knowledge 21 concerning whether or not you were engaging in 22 constitutionally protected tpeech. I don't know if you 23 were flying banners or displaying signs in February of 24 2014. So, I don't know if they were critical of your 25 opponents or otherwise carried political messages. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 221 1 And then, I have no personal knowledge with 2 regard to the statement that the Town threatened 3 Plaintiff with adverse action, including code 4 enforcement hearings, carrying daily fines not to exceed 5 $500 per sign per day if he did not remove his signs and 6 otherwise cease such political speech. 7 Q. Before we go to 15, let me ask you this, were you 8 aware that I was arrested in the Town? 9 A. When? 10 Q. I'm going to say three to four months ago. It 11 was after a 5:00 o'clock meeting, one of the late 12 meetings, and they had two boards in the lobby and a lot 13 of propaganda. You may have even been there that night, 14 although I don't really remember you. 15 A. No, I wasn't there. 16 Q. Okay. 17 A. I didn't see you get arrested. 18 Q. Okay. 19 A. No. 20 Q. And I was told later on that the only reason that 21 I was arrested is because they knew I was going to sue 22 the Town for their conduct and they wanted to get on an 23 even playing ground, playing field? 24 A. I have no knowledge. 25 Q. You have no knowledge of that? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 222 1 A. No. 2 Q. Okay. Fair enough. 3 A. Where was I again? 4 MR. GOLDSTEIN: Fifteen. 5 BY MR. O'BOYLE: 6 Q. Fifteen. 7 A. Fifteen, right. As a result of the removal of 8 his campaign signs, the threats of official adverse 9 action of his political signs were not removed and other 10 conduct that -- by the Town. Plaintiff filed another 11 federal action against the Town in March 2014. 12 I had no personal knowledge of that. 13 Q. Okay. 14 A. After the March 2014 election, the Plaintiff 15 continued to criticize Town officials with banners on 16 the side of his truck which he would park from time to 17 time at Town Hall to ensure maximum visibility and 18 political effectiveness because Town Hall is the seat of 19 the Town's legislative judicial and executive branches. 20 As I told you at some point, I became aware of a 21 fact that a sign -- regarding the towing of a truck, but 22 that's my work product. I have no knowledge of the 23 March elections, your criticizing Town officials with 24 banners on the truck during the election or any of that. 25 Q. Okay. Let me, before we go on to the next one, Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 223 1 are you a member of the Gulf Stream Racquet and Tennis 2 Club? 3 A. No. 4 Q. Are you a member of any clubs? 5 MR. GOLDSTEIN: Object to the form. 6 BY MR. O'BOYLE: 7 Q. In that area, the Delray? 8 A. No. I was a summer member of the Ocean Club many 9 years ago when my children were at Gulf Stream, but they 10 only liked that when they were little. 11 Q. Does your wife know my wife, Sheila? 12 A. I believe they did. 13 MR. GOLDSTEIN: Object to form. 14 BY MR. O'BOYLE: 15 Q. They're both still alive, right? 16 A. I mean, they knew each other -- they know each 17 other. They were at Gulf Stream School as mothers 18 together. 19 Q. And do they still spend time together to your 20 knowledge? 21 A. Not that I'm aware of, but I don't ask my wife 22 her -- about her friends and who she talks to or -- 23 unless she tells me something. I know she held your 24 wife in very high regard. 25 Q. Has she said anything derogative, if that's the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 224 1 right word, about my wife to your knowledge? 2 A. Who is that? 3 Q. Your wife? 4 A. Well, I wouldn't divulge my husband/wife 5 communications, but I can tell you that I'm remembering 6 back from many years ago and she had very high regard 7 for Sheila. 8 Q. And you didn't want to answer that because of the 9 spousal privilege? 10 A. Well, I don't want to go into -- I don't want to 11 open the door to talking about everything I talk to my 12 wife, but that was said not in confidence. 13 And I remember, if I'm not mistaken, that your 14 wife and my wife were room mothers, maybe, for fifth 15 grade for your daughter -- one -- your daughter and one 16 of my daughters, and they worked together. 17 Q. Did you ever invite or did anyone in your family 18 ever invite anyone over to your home for a -- for 19 something social? 20 A. Anyone over or anyone in your family over? 21 Q. Anyone over for something social who you had 22 charged with the unauthorized practice of law? 23 MR. GOLDSTEIN: Object to the form. 24 THE WITNESS: Are you referring to Jonathan, 25 obviously, is that the person you're talking Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 225 1 about? 2 Has he ever been to my house for social 3 events? Not that I'm aware of. 4 BY MR. O'BOYLE: 5 Q. Okay. 6 A. I don't remember -- I don't remember -- I don't 7 think Jonathan was in any of my children's classes and I 8 don't remember Jonathan as a young man at all. 9 Q. How about Sarah O'Boyle? 10 A. Sarah had been to our house and Berkeley had been 11 to your house, I believe, when they were in fifth grade 12 or something. How many years ago is that, fifteen? I 13 don't know. I'm getting -- at 62, I'm not wanting to go 14 count anymore. 15 Q. Only two more than me, so -- 16 Well, we stopped at 16, did we? 17 A. No, we made it to 62 and 64. 18 Q. You're a funny guy. 19 A. So, let's see, 16. 20 MR. GOLDSTEIN: I think we're seventeen. 21 THE WITNESS: Seventeen, okay. That was a 22 good year, too. 23 These are just a few of many examples of 24 Plaintiff's exercise of constitutionally 25 protected speech as it relates to the Town for Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 226 1 the last -- for, at least, the past two years 2 Plaintiff has displayed numerous signs and flown 3 numerous banners critical of the Town, its 4 mayors, its commissioners and other agents of the 5 Town. 6 Plaintiff has, likewise, attended numerous 7 town meetings and events during which he has 8 personally voiced his criticism of the same 9 group. 10 I think the first sentence is a legal 11 conclusion. I know you displayed banners for a 12 very brief period, I don't think it was anywhere 13 near two years. I think, it was like a month or 14 two. And I'm, again, going from like June 13th 15 to June 15th for two years. 16 I wasn't aware of any -- personally aware 17 of any signs that you were flying in Gulf Stream 18 or displaying in Gulf Stream. 19 The only thing that I can say is the work 20 product I have regarding learning about the 21 banners critical of the Town. I have never -- I 22 don't believe -- I'm trying to remember if I ever 23 attended any town meeting where I've seen you. 24 I've watched videos. I don't believe I've ever 25 seen you at a town meeting. I don't think you've Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 227 1 ever seen you at an event where you've criticized 2 the group. That's my best recollection. 3 BY MR. O'BOYLE: 4 Q. We can move on. 5 A. Okay. Plaintiff's above described constitutional 6 speech and lawsuits were not undertaken and filed to 7 harass the Town for any improper purpose. Rather, each 8 of the lawsuits filed by the Plaintiff against the Town 9 was filed to enforce a specific constitutional or 10 statutory right which Plaintiff contends was violated by 11 the Town or its officials. And the above described 12 speech was undertaken to voice legitimate concerns of 13 the Town's administration. 14 I have no personal knowledge of the lawsuits. I 15 don't think I've read one of them. 16 I don't know what your purpose was for filing 17 these lawsuits. I don't know if you contend that your 18 rights were violated by the Town in those lawsuits. And 19 I don't know if you were expressing legitimate concerns 20 because I've never looked at those lawsuits. 21 Q. Let me ask you this, are you familiar with the 22 public records law in Florida, Chapter 119, would that 23 be a true statement? 24 A. I believe so. 25 Q. Okay. And you consider yourself and/or your firm Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 228 1 a contractor of the Town of Gulf Stream? 2 A. That's a legal conclusion which I'm not going to 3 provide you a legal opinion I am not going to provide 4 you. 5 MR. GOLDSTEIN: Object. 6 BY MR. O'BOYLE: 7 Q. Okay. Do you have any public records, either 8 personally or in your firm that would be available to a 9 requestor in connection with the Town of Gulf Stream? 10 A. That's a legal conclusion. I'm not going to give 11 you my legal opinion. 12 Q. So, if I made a request for a legal document as I 13 made to your counsel and you had it -- I say "you", I'm 14 using you or your firm interchangeably, would I receive 15 it? 16 MR. GOLDSTEIN: Object to form. 17 THE WITNESS: That's a legal conclusion that 18 would depend on a number of factors. I'm not 19 going to give you my legal opinion even in a 20 vacuum which is what you're asking for. 21 BY MR. O'BOYLE: 22 Q. What would be the number of factors? 23 A. Did it relate to my representation of the Town or 24 did it relate to the personal matter, a firm matter, 25 some other client matter. Am I a contractor. Is it -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 229 1 there are a number of factors such as those. 2 Q. It would relay to your representation of the 3 Town? 4 A. That would be one of the things, yeah. 5 Q. Well, would there be any others? 6 A. Yeah. Am I contractor or not as a legal matter, 7 a thresh hold matter. 8 Q. At the conclusion of a litigation -- and when say 9 "litigation", example, with myself and the Town of Gulf 10 Stream, and I ask you for your file, as you sit here 11 without looking at the law, do you believe that you 12 would have the obligation to produce it? 13 MR. GOLDSTEIN: Object to the form. 14 THE WITNESS: You're asking me yet, again, 15 for an opinion. And I have a legal opinion, but 16 I'm paid to give my legal opinion to Gulf Stream 17 and I'm going to give my legal opinion to Gulf 18 Stream. 19 You have to either pay your lawyer or ask 20 your son to come up with your own legal theories 21 in this case. 22 I represent opposing parties. I would think 23 by now you would understand that because we've 24 gone through this. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 230 1 BY MR. O'BOYLE: 2 Q. I do understand it. And I guess the best way to 3 answer it is for me to make a public request this 4 evening to you and your firm, whereupon, we'll expect a 5 response. And if we don't expect a response, you could 6 expect a response. 7 A. Mr. O'Boyle -- 8 MR. GOLDSTEIN: No, there's no question 9 pending. 10 THE WITNESS: Yes. What's the question? 11 MR. GOLDSTEIN: Move to strike. 12 BY MR. O'BOYLE: 13 Q. The question is, it would be a post that I 14 wouldn't want to take. All I want to know is to have a 15 sense of how you would address such a request. And it 16 sounds like to me that you don't want to tell me. 17 MR. GOLDSTEIN: Asked and answered. 18 THE WITNESS: Is that a question? 19 BY MR. O'BOYLE: 20 Q. Yes. 21 A. So, you want to know how I would address 22 something in the future without seeing it or doing any 23 research on knowing anything about it? 24 And all I can say is, that's speculation and I 25 can't answer that, Mr. O'Boyle, with all due respect. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 231 1 Q. And with all due respect to you, Mr. Sweetapple, 2 anytime a records request is made, it's in the future. 3 It's not in the past, it's in the future. 4 If I make a records request to Mr. Goldstein, 5 it's in the future. 6 A. Is that a question? 7 MR. GOLDSTEIN: No, it's not a question. 8 MR. O'BOYLE: Yes, it is a question. 9 MR. GOLDSTEIN: No, it's not. If you'd like 10 to form it in the phrase of a question, move to 11 strike your commentary. 12 BY MR. O'BOYLE: 13 Q. Let me do it again and waste some time as 14 Mr. Goldstein says. 15 MR. GOLDSTEIN: Object to commentary. Move 16 to strike again. 17 MR. HOCHMAN: Mr. O'Boyle, let me just let 18 you know it's after 5:00. You know we'd like to 19 get out of here before 6:00. And I don't think 20 you asking this witness about how he would handle 21 a future public records request is, in any way, 22 relevant to any allegation in the Second Amended 23 Complaint or any amended complaint. 24 Please, I'm asking if you can just go over 25 the issues that are in the lawsuit rather than Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 232 1 create new issues, it would be greatly be 2 appreciated. 3 MR. O'BOYLE: And I would love to 4 accommodate you, but I have a job to do and I 5 intend to do it. 6 And I apologize. If you went ahead and made 7 a schedule, remember with Ms. Randolph was 8 supposed to be here, she isn't, that was supposed 9 to be until 8:00 o'clock at night. 10 So. If you made other plans, shame on you. 11 MR. HOCHMAN: You say 8:00 o'clock at night, 12 why do you say that? 13 MR. O'BOYLE: Because she was supposed to 14 start at 4:30 and end at 8:00 p.m. 15 MR. HOCHMAN: I was not aware of that. 16 MR. GOLDSTEIN: Neither party agreed to 17 having a deposition and stay until 8:00 o'clock. 18 You set that on your own. 19 MR. HOCHMAN: And the notion was that if you 20 had a few questions to ask her, there would be 21 sufficient time to ask her, but not for an 22 extended deposition on a Friday right before a 23 holiday weekend. I'm just asking you as a matter 24 of an accommodation -- 25 MR. O'BOYLE: I heard you and I'm -- I told Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 233 1 you yesterday when you walked out or the day 2 before whatever it was, that I was going to do 3 the best I can and I got as close to the end as I 4 could and you decided to walk out. And that was 5 your prerogative and you can walk out now. 6 That's your prerogative or walk out anytime. 7 I'm going to keep on doing this. The more 8 we have these discussions, the more time we're 9 going to need. So, I would ask you to take a 10 chill pill. 11 MR. HOCHMAN: I'm going to make one last 12 comment, with respect to the issue of future 13 public records requests, that's what I'm talking 14 about. If you want to go back to what you marked 15 as Exhibit Number 1 and talk about the 16 allegations, then that I believe it is relevant 17 and you can continue on that path. 18 MR. O'BOYLE: Okay. Have you been taking 19 all this down? 20 THE COURT REPORTER: Yes. 21 MR. O'BOYLE: Okay. I am not going to 22 bother you to go all the way back then. 23 Where were we, Mr. Sweetapple? 24 THE WITNESS: I'm following your lead at 25 this point. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 234 1 BY MR. O'BOYLE: 2 Q. Where did we leave off? I know how disruptive 3 Mr. Hochman can be, but let's try to -- 4 A. Well, you were asking me about future public 5 records requests on which -- and what obligations there 6 are legally to provide files once litigation is 7 concluded, which has nothing to do with the pleading 8 that's in front of me. 9 Would you like me to go back and try to figure 10 out where we were before you diverted into that subject? 11 MR. GOLDSTEIN: Nineteen. 12 THE WITNESS: Nineteen. 13 BY MR. O'BOYLE: 14 Q. Yeah, if you would like to do that. 15 A. Okay. So, I think -- I think Mr. Goldstein is 16 correct and I think 19 is the next paragraph. 17 Q. Okay. 18 A. Plaintiff used the above described lawsuits as 19 meritorious and necessary to enforce State and Federal 20 laws and with respect to, at least, some of the public 21 records lawsuits filed by Plaintiff, the Town's current 22 Mayor, Scott Morgan, has stated on the record that he 23 agrees the cases have merit. 24 I don't know what your view is of the above 25 described lawsuits. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 235 1 I don't know if they're necessary to enforce 2 State and Federal laws. 3 And I don't know what Mr. Morgan has stated on 4 the record, and I don't know what record you're 5 referring to. 6 Q. The Beatles White album. 7 A. If it's in a court proceeding or city meeting, 8 what you're referring to. 9 Q. I'm joking. Let's go to twenty. 10 A. Okay. In response to the Plaintiff's lawsuit, 11 the Town, through the actions of its mayor, its town 12 manager, the town police force and Sweetapple have 13 endeavored to forego Defendant/Plaintiff's various cases 14 on the merits and have opted instead to engage in 15 threats, intimidation and harassment designed to cause 16 Plaintiff to dismiss his lawsuits against the Town. 17 Okay. So, I don't believe I have endeavored to 18 forego defending the lawsuits I'm handling on the 19 merits. I think I have vigorously attempted to defend 20 those cases on the merits. 21 I don't think I have ever spoken to you, written 22 to you, threatened you, intimidated you, harassed you, I 23 don't think I've ever done anything to cause you to 24 dismiss your lawsuits against the Town. 25 And let me go on, next page. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 236 1 Q. Wait, wait, wait. In Paragraph 20, if I'm 2 correct, that you told Ms. O'Connor that you were going 3 to get to me through my son, would you consider that a 4 threat? 5 A. First of all -- 6 MR. GOLDSTEIN: Object to the form. 7 THE WITNESS: -- a threat is when you say 8 something to someone and I haven't spoken to you 9 ever about any of this litigation, I don't 10 believe, at any time, nor have I made any threats 11 to your counsel, nor have I intimidated you or 12 harassed you. 13 I did not say to Ms. O'Connor in front of 14 anyone or at any other time that I was going to 15 get to you through your son. 16 I have a pending -- I had a pending motion 17 to disqualify the O'Boyle Law Firm and you had a 18 reaction to it, apparently. And if you deemed 19 that as intimidation or threat or harassment, I'm 20 sorry, that's called a legal proceeding. 21 22 BY MR. O'BOYLE: 23 Q. If it were stated out in the hallway of a public 24 building, a courthouse, that's called a legal 25 proceeding? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 237 1 MR. GOLDSTEIN: Object to form. 2 THE WITNESS: No, I'm saying the Motion to 3 Disqualify the O'Boyle Law Firm is part of a 4 legal proceeding. 5 BY MR. O'BOYLE: 6 Q. I don't -- I don't know whether -- 7 A. That's not harassment or threatening or 8 intimidation, so I don't know what you're referring to. 9 And I did not say that I was going to get to you through 10 your son. 11 Q. Would you like to -- 12 A. No, no. In fact, I -- 13 MR. GOLDSTEIN: Object to the form. 14 THE WITNESS: I spent time with your son and 15 had a nice chat with him at one of the 16 depositions. I have no desire to hurt your son 17 or to hurt you. 18 I have a desire to do my job and I have to 19 do my job as the facts come to me. And when I 20 got involved in this case, I had no idea that 21 defending public records cases was going to 22 result in someone calling me in July and telling 23 me they wanted to report criminal or fraudulent 24 behavior. 25 But, Mr. O'Boyle, I don't make my cases. I Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 238 1 don't choose my facts. I don't choose my 2 witnesses. What I do do, is I try to ethically 3 and competently discharge my duty to my client. 4 And unfortunately, I have to do it regardless of 5 who the other side is. 6 BY MR. O'BOYLE: 7 Q. And I'm not -- I'm not disputing that. 8 A. Well, thank you. I'm glad you're not disputing 9 that. 10 MR. GOLDSTEIN: There's no question pending. 11 BY MR. O'BOYLE: 12 Q. You said in July something about criminal and 13 then another type of behavior. 14 MR. GOLDSTEIN: Objection, mischaracterizes 15 his testimony. 16 THE WITNESS: What are you referring to? 17 MR. O'BOYLE: Young lady, would you read 18 that back to make Mr. Goldstein happy' - 19 MR. GOLDSTEIN: I know what his testimony 20 is, you don't need to make me happy and read back 21 my client's testimony. 22 MR. O'BOYLE: Would you kindly. 23 MR. GOLDSTEIN: You need to ask the next 24 question. 25 MR. O'BOYLE: Would you kindly read that Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 239 1 back, please. We want to see him have a smiley 2 face. 3 MR. GOLDSTEIN: Move to strike commentary. 4 THE WITNESS: I believe I said that Mr. -- I 5 didn't choose to have Mr. Chandler call me and 6 tell me that he wanted to report criminal or 7 fraudulent conduct to me. 8 When I got involved in this litigation, I 9 thought it was going to be public records 10 litigation. I didn't know public records were 11 going to be in this dimension. I didn't -- 12 MR. GOLDSTEIN: There's no question. 13 BY MR. O'BOYLE: 14 Q. So, Mr. Chandler said that I was engaged in 15 criminal activity. 16 MR. GOLDSTEIN: Asked and answered. 17 THE WITNESS: When Mr. Chandler called me, 18 he called me, he said, to report criminal or 19 fraudulent activities involving Cafi. And then 20 that's when I went into discussions immediately 21 about whether or not he had an attorney. 22 And then I believe his affidavit and his 23 statements discuss the fact that -- I think his 24 affidavit discussed the fact that he called me 25 and said that. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 240 1 BY MR. O'BOYLE: 2 Q. Did you advise him to go to the State Attorney's 3 Office? 4 A. No. 5 Q. Why not? 6 A. Because I'm not his attorney. 7 Q. You're not his baby-sitter either. The time that 8 you spent on that huge interview and on the affidavit 9 and so forth, if someone does something wrong and you're 10 a lawyer, aren't you supposed to report it? 11 MR. GOLDSTEIN: Object to the form. 12 THE WITNESS: In terms of -- in terms of 13 Mr. Chandler's statement, I went and took his 14 sworn statement and I did not give him any legal 15 advise. I took it and, of course, then 16 appropriately investigated it. 17 BY MR. O'BOYLE: 18 Q. Why did you not go to the State Attorney's Office 19 with that information? 20 A. I'm not going to disclose the Town's work product 21 or communications with law enforcement with regard to 22 this matter. 23 Q. It wouldn't be the Town, would it? It would be 24 you, personally, as a member of the Bar. 25 Don't you have an obligation as a member of the Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 241 1 Bar? 2 A. I'm not going to give you a legal opinion on 3 that. 4 Q. All right. 5 A. Read the rules regulating the Bar. Speak to your 6 son. It discusses what type of criminal conduct. If 7 it's your client you have to report, not some other -- 8 there's no special duty -- 9 MR. GOLDSTEIN: Enough. 10 MR. HOCHMAN: Ms. Court Reporter, I'm going 11 to ask for another excerpt which is the beginning 12 of this discussion about Paragraph 20 all the 13 testimony through this request, thank you. 14 Is this the third or fourth? 15 THE COURT REPORTER: Fifth. 16 BY MR. O'BOYLE: 17 Q. Which number? 18 MR. GOLDSTEIN: Twenty-one. 19 THE WITNESS: Ready for 21. 20 BY MR. O'BOYLE: 21 Q. Yeah. Is your voice all right? 22 A. Pardon? 23 Q. Is your voice all right? 24 A. I'm starting to get a little horse. 25 Q. Because Mr. Goldstein is answering all your Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 242 1 questions. 2 MR. GOLDSTEIN: I was trying to help a long. 3 THE WITNESS: I appreciate your asking 4 because my voice is getting a little horse, but I 5 don't want to drink a lot of water because then I 6 need another two -minute break. 7 BY MR. O'BOYLE: 8 Q. Good enough for me. 9 A. A vicious circle. 10 Q. So, 21? 11 A. I think we're at the top of -- I was turning to 12 Page 5, so we were at constitutionally protected speech, 13 critical of the Town and its agents and ultimately move 14 from the Town due to pressure against Plaintiff and his 15 family. 16 I have done nothing -- as to the allegation as to 17 me I've done nothing. I never asked you to cease your 18 constitutionally protected speech in any regard nor have 19 I asked you any of your attorneys to do that. 20 I have never, in any way, asked you to move from 21 the Town due to the pressure against Plaintiff and his 22 family. 23 So, I don't know what you're referring to there. 24 Q. Okay. Let me ask you this, did you ever threaten 25 Mr. O'Hare or any of his lawyers by saying something Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 243 1 akin to, if you drop your lawsuits, we'll keep you out 2 of the RICO? 3 And when I say "you", I'm talking about 4 Mayor Morgan, the Town, Ms. O'Connor, if you drop your 5 lawsuits, we won't file a RICO suit against you. Do you 6 remember anything like that? 7 MR. GOLDSTEIN: Object to the form. 8 THE WITNESS: I'm not going to disclose any 9 communications from the September 3rd mediation. 10 So, in terms if you want to know about 11 communications with Mr. Hannah, because I had no 12 communications with Mr. O'Hare directly other 13 than, I believe, in the September 3rd -- my 14 meetings with Mr. Hannah were without Mr. O'Hare. 15 And in meetings with Mr. Hannah, I indicated 16 to him that the Town was considering and intended 17 to go forward with a case against Mr. O'Hare for 18 being part of an alleged scheme to defraud that 19 had been described by Mr. Chandler. 20 BY MR. O'BOYLE: 21 Q. Why was Mr. Chandler not named in the RICO suit 22 considering his history, such as, fraud on the court, 23 such as, false indigent statements, such as, the most 24 prolific request of records in the state to my 25 knowledge, such as, being the one who made the request Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 244 1 to Wanton Group, as well as, hundreds of other third 2 party vendors, contractors, that are liable under 119? 3 MR. GOLDSTEIN: Object to the form. 4 THE WITNESS: First of all, you're calling 5 for a legal conclusion. 6 BY MR. O'BOYLE: 7 Q. No, I'm not. 8 A. A legal opinion as to why something wasn't done. 9 Second of all, that wasn't my ultimate decision, 10 so I can't answer that. 11 Q. Whose ultimate decision was it? 12 A. The Town and consultation with the Richmond Greer 13 Law Firm. And I believe -- I can't remember without 14 looking if the Jones Foster Law Firm was also a filer of 15 record, but I -- I just can't remember. 16 Q. By the way, whose the town attorney for the Town 17 of Gulf Stream, it's not you, is it? 18 A. I don't believe so. 19 Q. Who is it? 20 A. I think that would call for a legal conclusion. 21 Q. As well? 22 A. Yeah. I mean, I don't know if there's a town 23 attorney. I heard you ask those questions before. 24 Don't know if there's a town attorney. 25 Q. Was it Morgan's decision to not go after Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 245 1 Joel Chandler? 2 MR. GOLDSTEIN: Object to the form. 3 THE WITNESS: I am not going to disclose any 4 communications that I had with my client with 5 regard to any matter. 6 BY MR. O'BOYLE: 7 Q. Chris O'Hare, what did he do, in your opinion, 8 for him to get, for lack of a better way of saying, 9 sucked into this RICO suit? What did he do? 10 MR. GOLDSTEIN: Object to the form. 11 THE WITNESS: I'm not going to apprise you 12 with my legal opinion. 13 MR. GOLDSTEIN: Go ahead. 14 THE WITNESS: And I am not going to provide 15 you with my work product. 16 BY MR. O'BOYLE: 17 Q. Okay. Go to the next number now. 18 A. Yes, sir. If Mr. Goldstein will tell me what 19 that is? I think I know, it's probably 21. 20 MR. O'BOYLE: He'll probably answer for you. 21 MR. GOLDSTEIN: Object. Move to strike 22 commentary. 23 THE WITNESS: So, we have Morgan's June 2, 24 2014 letter is the next heading. Twenty-one, in 25 a June 2, 2014 letter from Morgan to all Town Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 246 1 residents, Morgan noted that the Town's general 2 fund reserves had fallen below an acceptable 3 number and blamed this occurrence on the lawsuits 4 filed by Plaintiff and another Town resident. 5 I don't remember if I had even seen that 6 letter, so -- I don't live in the Town, I don't 7 go to the Town very often. 8 Twenty-two? 9 BY MR. O'BOYLE: 10 Q. Are you aware that Joel Chandler sent a letter, I 11 think an e-mail actually, to Chris O'Hare absolving him 12 from any obligations, liability and the like in 13 connection with the RICO suit and urged the City, or the 14 Town, to let him out of the suit? 15 MR. GOLDSTEIN: Object to the form. 16 THE WITNESS: I am aware that Mr. O'Hare 17 wrote a message that was read to the commission. 18 BY MR. O'BOYLE: 19 Q. Mr. O'Hare or Mr. Chandler? 20 A. Mr. Chandler regarding Mr. O'Hare. 21 Q. Right. And would I be correct in saying that 22 that met deaf ears? 23 MR. GOLDSTEIN: Object to the form. 24 THE WITNESS: No. 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 247 1 BY MR. O'BOYLE: 2 Q. Okay. What was the result that e-mail or letter 3 being read to the commission? 4 MR. GOLDSTEIN: Object to the form. 5 THE WITNESS: In terms of the decision made 6 to go forward? 7 BY MR. O'BOYLE: 8 Q. Or to not erase him from the turmoil. 9 MR. GOLDSTEIN: Form. 10 THE WITNESS: Mr. O'Hare was named in the 11 suit, but I'm not going to disclose to you my 12 communications with Mr. Chandler, my work 13 product with Mr. Chandler about Mr. O'Hare and 14 about Mr. Raider because that's work product or 15 their financial arrangements, I'm not going to 16 disclose any of that. 17 BY MR. O'BOYLE: 18 Q. But Mr. Chandler sent Mr. O'Hare a communication, 19 you are not suggesting that's privileged, are you? 20 A. No, not at all. I'm saying that I am not going 21 to disclose my work product and my interviews with 22 Mr. Chandler before he sent that and that's all I'm 23 saying. 24 Q. Okay. Now, you're aware that we took 25 Mr. Chandler's deposition on Tuesday of this week? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 as 1 A. I am aware that it was finished on Tuesday of 2 this week, but I know nothing about it. 3 Q. If I told you he called the Town of Gulf Stream a 4 bunch of criminals, what would you say about that? 5 MR. GOLDSTEIN: Object to the form. 6 THE WITNESS: That would be speculating. I 7 haven't had a chance to think about that. 8 My first reaction would be that people 9 should not speak that way even in depositions. 10 That's reckless, irresponsible to any group of 11 people. To say someone's a criminal, you know, 12 like that, I personally, you know, find that kind 13 of conduct irresponsible, but that's my own 14 personal reaction. 15 I'd have to hear the context and who the 16 people he was referring to and what the conduct 17 was, but the minute you hear a group of people 18 and they're all something, my dinger goes up. 19 BY MR. O'BOYLE: 20 Q. Is that your laymen's opinion then? 21 A. That's my laymen's opinion. 22 Q. Thank you. 23 A. That's all I can give you. 24 Q. No, I understand. Thank you. 25 And that statement that you just made, would that Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 249 1 apply to me. If someone were to call me a criminal? 2 MR. GOLDSTEIN: Object to the form. 3 THE WITNESS: Without getting into a 4 laymen's opinion, we're getting into my legal 5 opinion. And my legal opinion is an informed 6 opinion that's a result of quite a bit of work 7 product that I'm not going to share with you. 8 BY MR. O'BOYLE: 9 Q. Joel Chandler, you, in my opinion, have much more 10 knowledge about him then you do about me. He used the 11 term criminal with the Town, as I recall, were a bunch 12 of criminals or something like that, I forget the exact 13 words. 14 And what you said is, my word now, inappropriate, 15 you don't like that kind of stuff, shouldn't be said at 16 a deposition and so forth. 17 A. My first reaction is that's offensive to -- to 18 latent group of people, public officials, unless you 19 have some evidence, you are making it for a public 20 purpose. 21 I know of no basis for calling the people I have 22 dealt with at Gulf Stream criminals. I find it 23 offensive. 24 Q. If Joel had called me a criminal, would you feel 25 the same way? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 250 1 A. Would I be offended? 2 Q. Would you feel the same way? I think you were 3 beyond offended, but yes, would you feel offended? 4 A. In light of the facts that Mr. Chandler reviewed 5 to me and in light of my work product, I'm not going to 6 give you my legal opinion as to how I would react. 7 Q. Can you give me your laymen's opinion just as you 8 did with -- as applied to the Town of Gulf Stream? 9 MR. GOLDSTEIN: Object to the form. 10 THE WITNESS: No, because with regard to 11 Mr. Chandler's statement, I don't know what it 12 related to, I have no idea of any facts. 13 You just give me, in a vacuum, something 14 that he said with regard to you, I have quite a 15 bit of work product and knowledge. And I'm -- I 16 don't have -- it's impossible for me to have an 17 lay opinion now. 18 BY MR. O'BOYLE: 19 Q. And that lay opinion would be emanated from a 20 glass mountain of evidence? 21 MR. GOLDSTEIN: Object to the form. 22 THE WITNESS: I don't know what you're 23 referring to about a glass mountain of evidence. 24 I mean, if you're saying that the evidence I have 25 is not reliable, that's -- that's a determination Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 251 1 to be made in different types of proceedings that 2 are -- 3 BY MR. O'BOYLE: 4 Q. In connection with this litigation. And again, 5 I'm looking at it in the sense of a corral where the 6 RICO, this litigation, the records litigation, so forth, 7 all fit in there. Do you feel it's appropriate for any 8 of the lawyers to call anyone a terrorist? 9 MR. GOLDSTEIN: Object to form. 10 THE WITNESS: I think in court I made a 11 reference to the fact that this was a form of 12 terrorism, that was with regard to the -- what I 13 explained to the court, I believed, was the 14 abusive filing. And I did not say terrorism in a 15 middle east sense, I said that the conduct was a 16 form of terrorizing this Town. 17 And for instance, one day I heard testimony 18 you served over 350 public records requests on 19 the scanner fax machine and shut it down so that 20 the Town could not use its machinery. And that, 21 to me, is terrorizing a Town. 22 Coming in and just inundating the Town with 23 public records requests for ulterior purposes, if 24 there are ulterior purposes, could be viewed, in 25 my lay opinion, as a form of terrorism, yes. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 252 1 BY MR. O'BOYLE: 2 Q. What does the Supreme Court say about that? 3 A. That's a legal -- a legal opinion and I'm not 4 going to give you my legal opinion. 5 And I believe that the growth of schemes to 6 defraud that are increasing, including legal activities 7 is an issue of law that, you know, I have an opinion on 8 and I'm not going to share it with you. 9 Q. That's fine. You said 350 requests. And again, 10 this is not, maybe, the exact words, but with the goal 11 being to shut the Town down, fax machine didn't work or 12 copy machine didn't work? 13 A. They couldn't use their equipment because you 14 just non -stopped kept sending public records requests 15 in. 16 And from a lay person, I would view that as an 17 attempt to abuse the law. And unfortunately, what 18 happens when people try to use the law in abusive 19 fashions, is that society sometimes has to change the 20 laws and then everyone suffers from the conduct of a 21 few. 22 Q. So, I think I understand. So, what you're saying 23 is, just as an example, the sixty thousand records 24 requests that Mr. Chandler made in the last 12 weeks is 25 not abusive? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 253 1 A. I am not going to give you my opinion on 2 Mr. Chandler's conduct because it's a legal opinion. 3 Q. But you just gave me an opinion on the 350? 4 MR. GOLDSTEIN: Object to the form. 5 THE WITNESS: Yes, I did. And I'm not going 6 to give you a conduct -- I don't -- I don't have 7 the details. I can give you a lay person's 8 opinion. 9 BY MR. O'BOYLE: 10 Q. Go ahead. 11 A. Which is something smells pretty rotten when 12 people make 60,000 public records requests from one 13 entity. Was it done in one week? Was it done in one 14 day? 15 Q. About twelve weeks. 16 A. Okay. Well, I can't -- I need -- I would need 17 more data. It's very concerning to me because, as I've 18 said in court, anyone with ten lawyers and ten word 19 processors could robocall public records requests a 20 thousand a minute to any government agency in the state 21 and based on the current status of the law, bring an 22 agency to its knees. 23 And unfortunately, when people file public 24 records requests to be kill shots to generate lawsuits, 25 in my lay opinion, that's abusive. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 254 1 When people then decide to target governments and 2 then file thousands of requests, from my lay opinion, it 3 appears abusive. 4 So, I have learned, in my 36 years of practicing 5 law, that there are people that have figured out how 6 they can abuse laws. And unfortunately, when they do 7 and it becomes detrimental, oftentimes the law changes. 8 So, I think that -- I think that that's my lay 9 opinion. 10 THE COURT REPORTER: I have to take a break. 11 THE WITNESS: Let's take a break. 12 MR. O'BOYLE: Certainly. 13 (Thereupon, a recess was taken; after which 14 the following proceedings were had:) 15 MR. O'BOYLE: I'm ready. 16 THE WITNESS: Okay. So, let's go. Which 17 number? 18 BY MR. O'BOYLE: 19 Q. Before we get into the numbers, you had mentioned 20 a bit ago that it was the Town's decision to proceed 21 with the RICO suit? 22 A. That's my understanding, yeah. 23 Q. Okay. And where did you get that understanding? 24 A. I saw there was a vote. I wasn't there, but I 25 read that somewhere. That's the main basis for it. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 255 1 Q. So, you saw there was a vote. 2 MR. GOLDSTEIN: Is there a question pending? 3 MR. O'BOYLE: Pardon? 4 MR. GOLDSTEIN: Wondering if there was a 5 question pending? 6 BY MR. O'BOYLE: 7 Q. Do we need to go through it again? If we 8 will -- if you do, I will? 9 MR. GOLDSTEIN: No, that's -- 10 BY MR. O'BOYLE: 11 Q. Okay. Did the Town pay you the $25,000 12 deductible on your insurance policy? 13 A. They didn't pay it to me. 14 Q. Did they pay it on your behalf, if not to you? 15 A. I believe so. 16 Q. Okay. And that was -- they paid the money and 17 this was in connection with their insurance company or 18 yours? 19 A. Mine. 20 Q. I see. And the $25,000 was applicable to what 21 litigation? 22 A. This litigation, I believe. 23 Q. The one that we're here for today? 24 A. Yes, Hm-hum. 25 Q. It wasn't in connection with the Sunshine Suit? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 256 1 A. No, no, I'm counsel in that case and 2 Mr. Goldstein just came in long after the deductible so 3 expired or exhausted. 4 Q. I'm sorry, can you please speak up? 5 A. Yeah, I'm sorry. The deductible and the 6 representation was in this case. Mr. Goldstein's firm 7 just came in to -- they never came into the Sunshine 8 case. 9 MR. GOLDSTEIN: We just entered an 10 appearance. 11 THE WITNESS: They entered -- oh, did you in 12 the Sunshine case? 13 MR. GOLDSTEIN: I think so. 14 MR. O'BOYLE: Please don't coach the 15 witness, Mr. Goldstein. 16 THE WITNESS: They entered an appearance in 17 the Cafi long after the deductible was 18 extinguished. 19 BY MR. O'BOYLE: 20 Q. I'm sorry, Mr. Sweetapple, Mr. Goldstein was 21 speaking while you were and I only have one good ear. 22 So, if you can give that another go, I'd appreciate it. 23 A. No. As I understand it, the $25,000 deductible 24 did not apply to anything other than the case that we're 25 deposing me in. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 257 1 Q. Okay. And that was your insurance company and 2 the twenty-five came from the Town, correct? 3 A. Yes. 4 Q. Okay. In the Sunshine case, you're a Defendant, 5 is that correct? 6 A. We've discussed that, yes. You asked me that, I 7 answered. 8 Q. And who's counsel for Robert Sweetapple? 9 A. My firm. 10 Q. Okay. And who is paying the bills for the 11 representation of Robert Sweetapple? 12 A. I don't think there have been any bills issued. 13 I think that time is being accumulated. 14 Q. Are you expecting the Town to pay the bills? 15 A. That's speculative. 16 Q. Well, it's not speculative. I'm asking, are 17 they? I'm asking you, are you expecting them? 18 MR. GOLDSTEIN: Object to the form. 19 Argumentative. 20 THE WITNESS: I'm keeping my records of my 21 time and I have no expectation. I would be 22 speculating. 23 BY MR. O'BOYLE: 24 Q. As a tax payer, I'm concerned about the amount of 25 money this is costing the Town. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 Are you intending to bill the Town or as you sit 2 here today, are you intending to bill the Town? 3 A. I'm intending -- 4 MR. GOLDSTEIN: Object to form. 5 THE WITNESS: I'm intending to actually bill 6 you. I filed a 57105 Safe Harbor Letter and I 7 don't believe that your claim that I'm a 8 government official and that my meeting with 9 Mr. O'Boyle -- I mean, Mr. Morgan with no other 10 government official there in anyway, violates the 11 Sunshine Law. 12 So, I'm actually intending to seek fees 13 against you. 14 BY MR. O'BOYLE: 15 Q. Just so I'm clear, there's a difference between 16 seek fees and collect fees. Which one are you intending 17 to do? 18 A. Both. 19 MR. GOLDSTEIN: Asked and answered. 20 BY MR. O'BOYLE: 21 Q. Both? 22 A. I believe that -- I believe that I have a bona 23 fide claim for fees in light of the complete lack of any 24 justiciable issue. And I'm -- based on what 25 Mr. Chandler told me, I expect you to be able to pay a Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 259 1 small fee award without even hesitating. 2 Q. Well, you can't believe Mr. Chandler in 3 everything he says, you know. 4 A. He was your employee, not mine. 5 MR. GOLDSTEIN: There's no question pending. 6 BY MR. O'BOYLE: 7 Q. Do you believe what Mr. Chandler -- do you 8 believe everything Mr. Chandler says? 9 A. Not everything he says, but -- 10 Q. What don't you believe? 11 A. When I say I don't believe everything he says, I 12 mean, I take everything with a grain of salt. 13 There's -- I can't think of anything that 14 Mr. Chandler has told me that wasn't bourne out by my 15 investigation or that was contradicted by anything that 16 I read off the top of my head I can't. 17 Well, I can say that in light of -- in light of 18 what I know about the interview I had with him 19 concerning Mr. O'Hare, I took what he put in his letter 20 to Mr. O'Hare and didn't believe it. That I can tell 21 you when saw that letter, I didn't believe it at all in 22 light of what I knew. 23 Q. And what letter would that be? 24 A. The letter that was read to the council or the 25 commission regarding why Mr. O'Hare shouldn't be Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 260 1 involved in the lawsuit. 2 Q. And now you successfully confused me. 3 A. You asked me if it there's anything that 4 Mr. Chandler told me that I didn't believe. And I'm 5 elaborating that the only thing I can think of is his 6 letter to the commission based on the things that he 7 told me about Mr. O'Hare, I took that with a complete 8 grain of salt and didn't believe it. 9 It contradicted what I had been told and I saw it 10 as just a coverup. 11 Q. Okay. Mr. O'Hare is a pretty big fellow. He 12 would be kind of hard to coverup, wouldn't he? 13 MR. GOLDSTEIN: Object to the form. 14 THE COURT REPORTER: Number 2. 15 (Thereupon, Plaintiff's Exhibit Number 2 was 16 marked for Identification.) 17 BY MR. O'BOYLE: 18 Q. Now, Mr. Sweetapple I don't have another copy of 19 that. 20 A. Okay. 21 Q. But I'm going to ask you what it is. 22 MR. GOLDSTEIN: Document speaks for itself. 23 THE WITNESS: This is a bill. It's 24 O'Boyle vs. O'Connor. And this looks like it was 25 sent out to Gulf Stream which I don't think has Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 261 1 happened since then because my office didn't 2 realize this is not a O'Boyle vs. Gulf Stream or 3 they saw -- probably saw O'Boyle vs. O'Connor, 4 Morgan, whatever, thought it was a Gulf Stream 5 case. 6 So, this is a bill or a matter that I'm 7 accruing time on. 8 BY MR. O'BOYLE: 9 Q. And is there a bill amount there? 10 A. $8,260. 11 Q. And if we were to short form the name of that, 12 would we call that the Sunshine Suit? 13 A. I believe this is a Sunshine Suit. 14 Q. Okay. And that's the same suit where you said 15 you were not billing, you were just collecting your 16 time? 17 A. Collecting, right. 18 Q. Is that correct? 19 A. Yes. It looks like they printed out a bill in 20 that matter and sent it. 21 Q. That is what it looks like, doesn't it? 22 A. Yeah. I hope it only happened once, but they 23 would certainly -- this is certainly -- this is not a 24 Gulf Stream Defendant case. 25 Q. But you sent the bill to Gulf Stream, didn't you? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 262 1 A. I didn't, but apparently my office did. 2 Q. And if Gulf Stream paid it, are you going to 3 refund it? 4 A. I'm going to give them a credit for this. 5 Q. Okay. And if there was another bill and Gulf 6 Stream paid it, are you going to fund it or give them a 7 credit? 8 A. Yeah. Anything -- this was -- this is a case 9 where I am personally a Defendant and Gulf Stream is not 10 a Defendant. 11 So, if Gulf Stream was improperly billed any of 12 those, I'll give them the credit. And if I don't 13 collect the fees from you, then I'll decide if I want to 14 bill Gulf Stream for my fees in defending myself from 15 going to their settlement conference. 16 Q. And who is defending or who's defending Gulf 17 Stream in this suit? 18 A. I think Mr. Hochman's firm. 19 Q. Didn't you just tell me that Gulf Stream wasn't 20 in this suit? 21 A. Mr. Morgan is in the suit. No, now you're 22 confusing me. This suit -- I think there's an insurance 23 council, either through the League Of Cities or through 24 the Jones Foster Law Firm, but I don't really know the 25 specifics of how they got their counsel. I can't Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 263 1 remember who it is. 2 Q. Okay. But we are squared away. 3 MR. O'BOYLE: Is that P2? 4 THE WITNESS: Yes, P2. 5 BY MR. O'BOYLE: 6 Q. P2 is an invoice from the Sweetapple firm for 7 $8,200 in connection with the Sweetapple firm 8 representing Mr. Sweetapple in the -- what we're calling 9 the Sunshine Suit? 10 A. Right. 11 Q. Right? 12 A. Yes. O'Boyle vs. O'Connor is a matter, but it's 13 not -- it's not a Gulf Stream Defendant case. 14 Q. Okay. You don't consider yourself a terrorist, 15 do you? 16 A. No. 17 MR. GOLDSTEIN: Object to form. 18 MR. HOCHMAN: Can I see the exhibit, please? 19 BY MR. O'BOYLE: 20 Q. Would you consider Mr. O'Hare a terrorist? 21 MR. GOLDSTEIN: Object to the form. 22 THE WITNESS: Do you want me to answer that 23 by disclosing what Mr. Chandler told me you and 24 he were doing? 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 �%." 1 BY MR. O'BOYLE: 2 Q. Sure. Mr. Raider, they were 3 A. Mr. Chandler told me that it was -- that, A, 4 Mr. O'Hare and you were both paying him for his training 5 and services, not just you and Mr. Raider as well. 6 And that it wasn't enough for you two to just go 7 make requests that were Al kill shots and to develop 8 your lawsuits by filing one or two requests, but he 9 withdrew from this involvement because your intent on 10 barraging Gulf Stream and making Gulf Stream an example 11 for all the other municipalities so that Cafi, when it 12 filed a request anywhere in the state, you could just 13 look to Gulf Stream and it would be a wasteland of 14 public records requests and he withdrew himself from 15 that. 16 But Mr. O'Hare was financially involved with him. 17 Mr. Raider, they were trained. He never said, oh, I 18 think it's great that Mr. O'Hare files sixty requests on 19 a Monday. He thought that this conduct was going to 20 result in the demise of public records law. He said he 21 liked Chris. 22 And when he was training Chris and Raider, that 23 Chris' wife came in and she heard what was going on and 24 said this is disgusting, what you all are doing is 25 disgusting. That's what Mr. Chandler told me, part of Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 265 1 what he told me, the evening after I took the statement 2 and asked him about Mr. O'Hare's involvement. 3 So, Mr. Chandler professed, at least, to have 4 absolute disgust for the idea of targeting the Town of 5 Gulf Stream and making it into a wasteland of public 6 records requests where it was clear that the records 7 couldn't even have been read in time, 350 requests, 8 sixty requests. I have somewhere there were over a 9 hundred requests immediately before the time I was 10 hired. And all that would do, Mr. Chandler said, would 11 be to destroy public records access in the state and he 12 was incensed by it. 13 So, I wasn't surprised, based on the financial 14 arrangements between Mr. O'Hare and you, that 15 Mr. Chandler tried to cover for Mr. O'Hare, but my -- my 16 opinion, my legal opinion in this case -- my legal 17 opinion in this case, which he kept asking me for and 16 asking me for became rather conclusively based on 19 everything I saw that there was a scheme to defraud, not 20 only the Town of Gulf Stream with the Cafi barrage and 21 the Cafi lawsuits, they're really just you, not Cafi, 22 there's no real Cafi from what I can see. Everything I 23 see shows there's no real Cafi, it's classic. 24 And then not only were you intent on bringing 25 Gulf Stream to its knees with public records requests Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 266 1 barrages as trained by Mr. Chandler despite his 2 statement that that should not happen or be done, but 3 then you went around the state with Mr. Grey and 4 Mr. Chandler and made these requests to over a hundred, 5 almost two hundred, I believe, government, state and 6 local. 7 Mr. Grey testified that the O'Boyle Law Firm was 8 paying him as a runner, a portion of the attorney's fees 9 collected in the lawsuits. That's his statement under 10 oath. I have the deposition transcript. 11 The whole goal was this "windfall scheme" because 12 when you -- when you made a public records request to a 13 Town and they saw what you were doing to Gulf Stream and 14 they saw the O'Boyle Law Firm and they saw Cafi, they 15 would just tower and write whatever check you wanted and 16 that you that you were asking for checks that were well 17 in excess of any time. You were filing a templet 18 complaint and demanding five thousand, ten thousand. 19 I saw evidence of claims for fees that were 20 denied by a court in Dade County where, I believe, you 21 demanded ten thousand and given 1700 recently. 22 So, you keep asking me for my legal opinion, 23 unfortunately, Mr. O'Boyle, I was hard pressed not to 24 decide, when I heard Mr. Chandler's statements, when I 25 read the exhibits, when I looked at what was happening Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 267 1 in these other government bodies, I was hard pressed not 2 to come to the legal conclusion that you were paying and 3 running and involved in, a long with these others, in a 4 scheme to defraud to obtain money and property from 5 state, government agencies. 6 And to set your son up in a law firm when he 7 wasn't even a lawyer, wasn't this young even a lawyer, and you had 8 to open the law firm here for him because you couldn't 9 wait to be the only client of this firm. He couldn't go 10 out -- this young man couldn't go out and go work for a 11 firm. He couldn't go out on his own with you supporting 12 him and get real clients. You're the client. You're 13 calling yourself a not-for-profit and you are providing 14 all of the litigation using this type of conduct. 15 How could I not conclude that this is a scheme to 16 defraud. How could I not conclude that, Mr. O'Boyle? 17 Q. Once you smoke a fatty, you can conclude 18 anything. 19 A. Well, I don't think I was smoking anything. 20 MR. GOLDSTEIN: There's no question pending. 21 MR. HOCHMAN: Let me have an excerpt and 22 this is going to be the last one that I ask for 23 which starts with Exhibit 2 being marked to 24 Mr. O'Boyle inviting the witness to -- I'm sorry, 25 to be requesting this next exhibit. Excerpt Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 a' 1 number six, thank you. 2 BY MR. O'BOYLE: 3 Q. Mr. Sweetapple, that was a wonderful speech that 4 you made. However, it is absent facts. Where you're 5 getting your information is absolutely beyond me. 6 It's clear to me now where the slander kicks in. 7 Absolutely you made it clear to me. And it's also clear 8 to me now where the First Amendment retaliation kicks 9 in. 10 That speech that you made was so nonsensical, so 11 absent facts, where you got it, I'm just at such a loss. 12 It was such nonsense. 13 A. Do you have a question, Mr. O'Boyle? how much you love your son and I know 14 Q. Yes. How are you feeling, Mr. Sweetapple? 15 A. I'm feeling sad. I'm feeling sad when I look at 16 this whole thing that you would put your son in this 17 position. I know how much you love your son and I know 18 how much I love my son. 19 And I know your son went to Gulf Stream School 20 and I know my wife cared greatly for your wife. And I 21 feel very badly that those documents were handed to me 22 and that that witness called me. 23 But when I look at this whole thing, the person I 24 feel the most sorry for is that young man sitting right 25 there because there was no need to turn your supposed Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 269 1 public record constitutional interest that you describe 2 that I just read about here into a business to make 3 money. 4 I didn't make up the kill shots. I didn't make 5 up the shake down. I didn't make up the "windfall 6 scheme". These are -- these are things that you know 7 full well are in -- that there's evidence of it that's 8 not just Mr. Chandler talking. 9 So, don't sit here and pretend that I'm making 10 things up, Mr. O'Boyle. I wish I were. I wish this 11 wasn't true. I wish you hadn't done this to this young 12 man. That's all I can tell you. 13 Q. I appreciate -- I appreciate very much if you 14 wouldn't sit here and make things up. 15 A. What have I made up? 16 MR. GOLDSTEIN: There's no question pending. 17 BY MR. O'BOYLE: 18 Q. I guess the mistake -- the big mistake that I 19 made is, I should have filed a complaint against my son 20 for the unauthorized practice of law. 21 A. You should have told him to wait. 22 MR. GOLDSTEIN: There's no question pending. 23 BY MR. O'BOYLE: 24 Q. Would you say that that is the thing to do or 25 would you -- what would you say? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 270 1 A. I would say -- 2 MR. GOLDSTEIN: Object to form. 3 THE WITNESS: I would say -- 4 MR. GOLDSTEIN: Argumentative. 5 THE WITNESS: I would say, Mr. O'Boyle, that 6 you might have considered having your son wait 7 until he became a Florida lawyer before you 8 decided you needed an O'Boyle Law Firm in your 9 very same office. 10 And that it -- that it might have been much 11 more prudent to have your son have real clients, 12 a real client, not have his father pretend to be 13 a not-for-profit and hire Mr. Chandler and 14 Mr. Grey to go make as many requests, kill shot 15 requests, as they need in order to generate cases 16 for his son's law firm. 17 And then you should have listened to 18 Mr. Chandler when he told you and Mr. O'Hare not 19 to target Gulf Stream and make it an example for 20 the state to see how you could abuse the law to 21 perpetrate a "windfall scheme" to generate monies 22 for your son. That's not the business model that 23 your son deserved, I'm sorry. 24 BY MR. O'BOYLE: 25 Q. Well -- Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 27] 1 A. And Mr. O'Boyle, tell me what fact Mr. Chandler 2 told me that is false and isn't corroborated by the 3 records that he provided to me, please? 4 Q. I certainly will. When do you intend to depose 5 me? 6 A. Well, tell me now because I'm making some very 7 serious statements about your conduct and you've told me 8 it's all false. Please tell me what's false? 9 MR. GOLDSTEIN: There's no question. 10 BY MR. O'BOYLE: 11 Q. If you want to agree to two dates, one where I 12 can depose you and one where you can depose me, I'm all 13 for it. And we can make the matter anything you want. 14 But boy, the hostility that I heard from you, now 15 it gets even more clear to me why you refer to me as a 16 racketeer. 17 A. Mr. O'Boyle -- 18 MR. GOLDSTEIN: Is there -- there's no 19 question pending. Move to strike commentary. 20 BY MR. O'BOYLE: 21 Q. Have you ever referred to me as a racketeer? 22 A. You've -- 23 MR. GOLDSTEIN: Asked and answered. 24 THE WITNESS: You've asked me that and I've 25 answered it. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 272 1 BY MR. O'BOYLE: 2 Q. Okay. Have you ever referred to me as anything 3 which would have a criminal connotation? 4 MR. GOLDSTEIN: Object to the form. 5 THE WITNESS: Calls for legal conclusion, 6 criminal connotation. 7 In my discussions with Mr. Hannah I did not 8 single out individuals. I said, this was a -- 9 based on what Mr. Chandler was describing, this 10 appeared to be a scheme to defraud under Florida 11 Statute 817. 12 I was talking to them about a Florida RICO 13 action and we were debating whether or not there 14 was a predicate act. 15 Mr. Hannah and I debated the law and 16 discussed whether this -- whether it was abuse of 17 process, whether this was a scheme to defraud. 18 So, I did discuss with Mr. Hannah the issues 19 regarding the bona fides of the conduct and 20 whether the conduct as described by Mr. Chandler. 21 I don't go around saying I believe you're a 22 racketeer, I believe you're a criminal. I'm a 23 lawyer. When I talk with another lawyer, I 24 discuss the facts that have been presented and 25 the legal theories that each of us believe apply Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 273 1 to the facts. 2 BY MR. O'BOYLE: 3 Q. Are you on a soapbox by any chance? 4 A. No. And I don't bear you hostility. I don't. 5 I'm more sad than anything. I wish you hadn't been 6 thrust this in this position. 7 Q. Then you ought to get out of it. 8 A. Well, no, I mean, I have -- 9 MR. GOLDSTEIN: There's not a question 10 pending. 11 THE COURT REPORTER: It's 6:36. 12 BY MR. O'BOYLE: 13 Q. You were talking about in Dade County that we -- 14 that something was violated. I don't remember -- 15 A. No, I said recently in Dade County there was a -- 16 in one of the Cafi cases there was a claim for -- about 17 $10,000 in fees. I believe the court found it was only 18 1,700 and the Appellate Court affirmed it. 19 Everything that you -- that Cafi has done is an 20 is a public record. 21 Q. I don't think everything that they've done, but I 22 don't know, I'm not involved with Cafi. 23 A. State wide, all the litigation, all the 24 correspondence, all of the monies that were collected, 25 they're all of public record. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 274 1 Q. I'm not disputing. I'm not involved in Cafi. 2 The only people I know who are involved in Cafi are you 3 and Mr. Chandler. 4 A. That was your testimony at your deposition and I 5 filed a motion after that. 6 MR. GOLDSTEIN: Nothing pending. 7 BY MR. O'BOYLE: 8 Q. In connection -- 9 MR. GOLDSTEIN: Move to strike. 10 BY MR. O'BOYLE: 11 Q. -- with Dade County, was there any crime to your 12 knowledge? 13 A. Based on Mr. Chandler's description of the 14 "windfall scheme" and his statement repeatedly to me and 15 his description of the communications and the e-mails 16 that went back and forth where he cautioned the firm not 17 to demand multiples of what was actually incurred when 18 there was not even an argument there could be a loan 19 star multiplier because there were no contingency fee 20 agreements. 21 He also described that the firm was settling 22 these cases without his permission, filing these cases 23 without his permission. The money all went to the law 24 firm, nothing went to Cafi. There was never a closing 25 statement. It was all done without his knowledge or Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 275 1 approval. He testified to or swore to, so -- 2 Q. Why would it have to have his knowledge and/or 3 approval? 4 A. Because -- 5 MR. GOLDSTEIN: Object to the form. 6 THE WITNESS: -- because he was told he was 7 going to be an executive -- he said he was told 8 he was going to be an executive director of a 9 real not-for-profit. 10 BY MR. O'BOYLE: 11 Q. Did you tap our phones? 12 A. No. 13 Q. How do you know that? 14 A. This is what he said. 15 Q. Oh, I see. 16 A. He testified -- 17 MR. GOLDSTEIN: There's no question pending. 18 BY MR. O'BOYLE: 19 Q. I see. I would like to just request that you go 20 to the Dade County State Attorney's Office and to the 21 FBI and explain to them what you just explained to me 22 and tell them that you would like to see this 23 investigated. Would you do that for me? 24 A. Is that a question? 25 MR. GOLDSTEIN: Is there a question pending? Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 276 1 BY MR. O'BOYLE: 2 Q. Would you do that for me is the question. 3 MR. GOLDSTEIN: Objection. Move to strike, 4 argumentative. Now badgering the witness. 5 BY MR. O'BOYLE: 6 Q. Pardon? 7 A. I'm not going to answer that question and I'm not 8 going to discuss my client's communications with law 9 enforcement with you. 10 Q. No, I'm not asking for your client's 11 communication. I'm asking you, which is future tense, 12 would you do that for me? 13 A. Well, that calls for speculation. 14 MR. GOLDSTEIN: Object to the form. Move to 15 strike. 16 BY MR. O'BOYLE: 17 Q. Calls for speculation? 18 MR. GOLDSTEIN: Move to strike. 19 MR. O'BOYLE: Would you have dinner tonight? 20 THE WITNESS: With you or -- 21 BY MR. O'BOYLE: 22 Q. No, no. I'm not going to invite you over to 23 Thanksgiving either. 24 A. Am I going to have dinner tonight? Not at the 25 rate we're going. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 277 1 MR. HOCHMAN: You are or are not? 2 MS. BAEZ: I am not going to answer your 3 question. 4 MR. HOCHMAN: Can you just please tell me if 5 we're at seven hours? 6 MS. BAEZ: I don't have the answer. 7 MR. HOCHMAN: I know, Ms. Baelz. But as a 8 matter of professional courtesy, you're a lawyer 9 and I'm a lawyer, I just want to find out if you 10 agree -- that you've been keeping time, you have 11 not represented anybody here, you're an observer. 12 MR. O'BOYLE: Okay. May I continue, please? 13 MR. HOCHMAN: You may, but I want to ask her 14 a question. Are we at seven hours? 15 MR. O'BOYLE: She said she's not going to 16 answer you. 17 THE WITNESS: The reporter's taking time. 18 MR. HOCHMAN: I'm then going to bring up to 19 the court if you're not going to act in a 20 professional manner, I asked you a question -- 21 MS. BAEZ: I am not being unprofessional. 22 I'm not the one being deposed here. 23 MR. HOCHMAN: I am asking you a question, do 24 you agree with me that it's approximately seven 25 hours? If you disagree, let me know and we'll Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 put it on the record. Do you disagree? 2 MR. GOLDSTEIN: Madam court reporter, how 3 much time do you have on this depo? 4 THE COURT REPORTER: I have that we 5 officially started at 9:25 and it is 6:41 right 6 now. And we took one hour for lunch. 7 THE WITNESS: So, how much time is that? I 8 can't do the math. 9 MR. GOLDSTEIN: About an hour half ago we 10 were at six hours. So, by my estimation there 11 was an hour half left. 12 MR. HOCHMAN: And if Ms. Baez disagrees with 13 me that -- 14 MS. BAEZ: Can I ask you why ask me. 15 MR. HOCHMAN: Well, you can disagree with 16 me -- 17 MR. GOLDSTEIN: Ms. Baez -- 18 MR. HOCHMAN: If you want to disagree with 19 me and say it's not seven hours, please do so. 20 MS. BAEZ: I am not -- 21 MR. HOCHMAN: Fine. So, there's no 22 disagreement on that side about whether or not 23 there's seven hours. Is anybody disagreeing? 24 MR. O'BOYLE: I'll let you know in a moment 25 how about that. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 279 1 MR. HOCHMAN: I'll give you a moment. 2 MR. O'BOYLE: Really? 3 THE WITNESS: Why don't we have the court 4 reporter give us her time. 5 MR. HOCHMAN: I want Mr. O'Boyle, if he 6 wants to put something on the record that he 7 didn't get his full-time with Mr. Sweetapple 8 that's fine. But I want to know what's going on 9 here, what's the basis for it? 10 We've been here since 9:00 o'clock. It's 11 quarter to 7:00, according to my -- 12 MR. GOLDSTEIN: 6:40. 13 MR. HOCHMAN: 6:40. 14 THE COURT REPORTER: I'm going to go off the 15 record. 16 (Thereupon, a recess was taken; after which 17 the following proceedings were had:) 18 MR. O'BOYLE: Madam court reporter, we are 19 now with the permission of Mr. Goldstein and 20 Mr. Hochman, we are going to adjourn the 21 deposition, if that's the right phrase, and let 22 Mr. Sweetapple go have dinner. 23 THE WITNESS: Well, I'm going to go to my 24 daughter's baccalaureate, but thank you very 25 much. Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 MR. GOLDSTEIN: Mr. Sweetapple, you have the 2 right to read or waive. 3 THE WITNESS: I'll read. 4 MR. HOCHMAN: And when I said before I'll 5 take that excerpt, the last one from when I asked 6 for it until take to the end, okay, from the 7 marking of Exhibit Number 2 to the end. 8 MR. GOLDSTEIN: To the end of the 9 deposition. 10 (Thereupon, the deposition was concluded at 11 6:44 p.m.) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 CERTIFICATE OF OATH 2 3 4 STATE OF FLORIDA ) 5 ) SS: COUNTY OF PALM BEACH ) 6 0 10 B-91 I, LISA GREENWELL, Court Reporter, Notary Public, State of Florida, certify that ROBERT A. SWEETAPPLE, personally appeared before me on the 27th day of May, 2016 and was duly sworn. 12 13 Signed this 15th day of June, 2016. 14 15 16 LISA GREENWELL, Merit Reporter 17 DAUGHTERS REPORTING, INC. 18 934 North University Drive Suite 224 19 Coral Springs, Florida 33071 20 21 22 Notary Public, State of Florida at Large My Commission expires: April 4, 2019 23 My commission No: FF 181085. 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 281 282 1 CERTIFICATE OF REPORTER 2 7 4 STATE OF FLORIDA ) ) SS: 5 COUNTY OF PALM BEACH) 11 7 I, LISA GREENWELL, Court Reporter, do hereby certify 8 that I was authorized to and did stenographically report the DEPOSITION of ROBERT A. SWEETAPPLE, that a review of 9 the transcript WAS requested; and that the foregoing transcript Pages 1 through 263 is a true record of my 10 stenographic notes. 11 12 I FURTHER CERTIFY that I am not a relative, 13 employee, or attorney, or counsel of any of the parties, nor am I a relative or employee of any of the parties' 14 attorney or counsel connected with the action, nor am I financially interested in the action. 15 16 Dated this 15th day of June, 2016. 17 18 19 LISA GREENWELL, Merit Reporter 20 21 DAUGHTERS REPORTING, INC. 934 North University Drive 22 Suite 224 Coral Springs, Florida 33071 23 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 283 1 ERRATA SHEET 2 3 4 Page No. Line No. Correction or Change 5 6 7 8 9 10 11 12 13 14 15 16 17 Witness 18 19 20 21 22 Sworn to and subscribed to before me this 23 day of 2016. 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 1 June 15, 2016 2 3 JOSHUA A. GOLDSTEIN, ESQUIRE 4 THE LAW OFFICES OF COLE, SCOTT & KISSANE,P.A. 1645 Palm Beach Lakes Boulevard, 2nd Floor 5 West Palm Beach, Florida 33401 6 IN RE: DEPOSITION OF Robert A. Sweetapple 7 TAKEN ON MAY 27, 2016 MARTIN E. O'BOYLE VS. SWEETAPPLE & MORGAN 8 9 Dear Mr. Goldstein , 10 This letter is to advise you that your client's 11 deposition, taken in the above -referenced style, has been 12 transcribed. Please have him read your copy and sign the 13 errata sheet. Please email to Daughters Reporting, Inc., at 14 daughtersreporting@gmail.com the errata sheet when completed. 15 16 Sincerely, 17 18 _ Lisa GrejFAwell, Court Reporter 19 Daughters Reporting, Inc. 934 North University Drive, #224 20 Coral Springs, Florida 33071 21 cc: Joshua Goldstein, Esq. 22 cc: Jeffrey Hochman, Esq. cc: Martin O'Boyle, Esq. 23 24 25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 A a.m 1:17 42:18 176:17 A1264:7 abandoned 85:17 ability 84:6 able 105:11 258:25 above-referen... 284:11 absent 268:4,11 absolute 169:10 169:14,18 265:4 absolutely 160:17 268:5,7 absolving 246:11 absorbing 124:11 abuse 252:17 254:6 270:20 272:16 abusive 251:14 252:18,25 253:25 254:3 accept 99:23 100:6 173:8 acceptable 206:23,25 219:17 246:2 access 111:5 265:11 accommodate 232:4 accommodation 232:24 accountant 22:23 23:1,18 accountants 24:3 accounting 22:21,23 23:9 23:10,16,17 26:16 accruing 261:7 accumulated 257:13 accurate 129:8 149:21 accuse 53:8 Accusing 105:13 acquired 4:19 acres 187:10 act 194:23,25 195:1 196:3 272:14 277:19 action 215:24 217:24 221:3 222:9,11 272:13 282:14 282:14 actions 212:20 212:22 235:11 active 70:7,14 78:9 85:11 110:6 actively 109:25 110:3 activities 32:19 34:12 88:25 137:17 186:19 187:7 197:15 197:17 239:19 252:6 activity 46:3,4 47:23 79:14 239:15 acts 214:11,21 add 39:24 159:4 added 159:19 addition 70:16 83:20 202:7 additional 89:19 address 70:9 81:4,7,24 82:1 86:24 87:2 102:15,19,20 103:14,17,19 106:3,5 107:19 107:20,25 108:7,8 109:2 111:6,16,23 112:3,4 188:16 188:22,23 230:15,21 addressed 102:25 103:2,5 adjoined 63:3 adjourn 279:20 adjourning 80:6 adjudicate 60:1 adjudicated 142:3 adjudicates 40:24 administration 227:13 admissible 165:2 admission 106:7 144:6 admitted 83:13 86:2 111:5 141:14 143:25 admitting 43:24 64:22 75:2 admonishing 12:15 ADV 135:15 adventurous 39:24 adverse 217:24 221:3 222:8 advertisement 19:5 advise 66:6,12 240:2,15 284:10 advised 37:24 advising 14:22 14:24 advisors 34:21 affidavit 32:22 62:9 239:22,24 240:8 affiliated 201:3 affirm 143:7 affirmative 116:11 169:23 affirmed 117:19 273:18 afternoon 171:20 agencies 189:24 190:11 191:11 193:18 203:13 205:25 206:3 206:17 267:5 agency253:20 253:22 agents 217:1,7 226:4 242:13 ago 19:3 28:11 40:2 55:3 74:15 123:12 169:8 179:4 189:18 221:10 223:9 224:6 225:12 254:20 278:9 agree 23:8,15 24:11 88:7 160:24 164:11 167:5,10 173:6 180:14 184:2 192:2,5 271:11 277:10,24 agreed 215:14 232:16 agreeing 214:19 agreement 130:25 165:3 215:15,20,21 215:24 216:2,4 agreements 116:12 274:20 agrees 234:23 Ah -huh 58:9 140:13 ahead 108:18 132:2 232:6 245:13 253:10 airplane 18:15 18:18 Airstreams 198:14 akin 243:1 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 I album 235:6 alert 172:17 alerting 13 1: 10 Alexander 135:16 alive 223:15 allegation 104:16 112:1 196:13 231:22 242:16 allegations 10:9 38:1 163:13 179:22 213:6 233:16 alleged 38:4 56:13 73:13 77:1 86:1 163:11211:2 211:14 243:18 allegedly 66:5 73:21 74:6 alleges 186:8 alleging 163:4,8 alley 121:16,18 allow 12:17 59:9 71:20 100:4 212:21 allowed 49:10 173:20 180:19 201:12 211:20 allows 90:16 Alpha 8:11,14 8:19 alternative 76:17 ambitions 197:2 amended 3:12 57:4,11,16,17 174:14 179:4 186:5 211:8,10 231:22,23 Amendment 13:19 14:18 141:19 142:16 181:10 186:19 187:6 215:9,10 268:8 America 136:23 American 146:16 amount 147:21 147:22 211:4 257:24 261:9 analysis 110:15 209:3 and/or 27:2 33:4 142:18 151:23 227:25 275:2 announced 166:3,5 216:15 216:20 ANSELMO 2:20 177:20 answer 6:8,13 10:8,10,12,16 10:18,24 19:25 20:7,16 24:25 26:9,10 43:25 60:5 62:15 63:16 66:8,15 66:20 69:1,4 69:17 71:3 72:20 76:25 77:16,20 81:18 81:20 82:6 83:3,5 92:3,6 92:13 98:13 99:7,10 100:20 105:10 106:20 107:11 108:10 115:13 120:24 121:7,17 122:13,17,24 124:1,13 125:5 125:9,12,16 128:2 133:6 141:23 152:16 168:20 169:5 170:21 171:1 179:24,24 184:23 185:19 194:5,15,19 203:8 205:3,12 213:7 224:8 230:3,25 244:10 245:20 263:22 276:7 277:2,6,16 answer's 122:11 answered 9:8 11:1 17:22 25:18 26:18 41:10,15 42:22 43:6 45:4 58:3 72:19 76:6 77:12 92:8,11 93:3 95:3 97:16 101:23 103:3 106:13 111:18 118:11 118:20 122:14 122:18,21 123:2 124:3 135:21 140:18 145:8,16,20 148:8 152:15 158:19 162:25 165:19 169:21 192:25 203:15 207:8 208:4,11 230:17 239:16 257:7 258:19 271:23,25 answering 34:4 41:1 71:20 105:12 241:25 answers 43:14 82:22 anticipation 133:9 anybody 104:21 132:19 145:10 153:9 174:13 197:8 277:11 278:23 anymore 225:14 anyone's 6:6 Anything's 199:22 anytime 112:24 231:2 233:6 anyway 24:10 49:6 50:24 79:24 141:8 220:2 258:10 apologize 33:24 71:1 184:11 232:6 apology 214:18 215:14 216:2 apparently 40:21236:18 262:1 appeal 134:9,12 134:14,22,25 135:3,6,7,11 138:20 162:5 appear 110:8 appearance 2:1 2:8,17 153:7 177:1,8,17 213:23 256:10 256:16 appeared 148:12 272:10 281:10 appearing 84:1 appears 163:7 254:3 Appellate 273:18 applicable 255:20 application 105:25 107:12 applied 141:11 167:14 196:6 250:8 applies 6:14 151:23 apply 167:16 249:1256:24 272:25 appreciate 6:11 8:7 20:17 55:2 63:1167:14 111:2 124:16 188:5 242:3 256:22 269:13 269:13 appreciated 232:2 apprise 245:11 appropriate 12:25 13:1 17:10 25:3 56:21 100:23 185:21220:1 251:7 appropriately 129:16 240:16 approval275:1 275:3 approximate 219:24 approximately 52:15 53:16 187:9,10 211:1 211:16 277:24 April 165:25 281:22 area 90:20 187:13 198:15 223:7 arena 153:17 argue 117:3 144:14 209:7,8 argument 36:3 74:11274:18 argumentative 257:19 270:4 276:4 arranged 50:11 171:21 arrangements 247:15 265:14 arrested 199:18 199:20 221:8 221:17,21 article 21:5 128:22 aside 41:17,19 70:23 asked 9:8,25 17:21 19:15 23:15 25:18 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 2 26:18 28:19 30:22 32:11 33:25 41:10,14 41:15 42:22 43:6,16,24 57:14 58:3 59:24 68:16 69:3,20 72:19 73:4 80:8 93:3 94:9 95:3 97:15 101:23 103:22 104:1,3 104:8 110:21 111:17 118:11 124:3 133:17 135:21 140:18 145:8,16,20 148:8 158:19 162:25 165:19 166:11 169:21 190:15 192:17 192:22,25 196:14 203:15 207:6 208:4,11 230:17 239:16 242:17,19,20 257:6 258:19 260:3 265:2 271:23,24 277:20 280:5 asking 6:1,4 9:2 10:1 14:17 17:1123:11,17 24:9,17,18 28:14,15,18,19 28:22 31:4 41:2,5,8 46:12 47:18,20 55:20 56:22,24 66:11 66:17 82:14 84:6 94:24 96:1197:13 98:6 99:6,7 116:10,17,18 116:18 120:3 123:17,20 126:7 127:16 133:20 137:10 145:17 158:20 160:25 161:2 165:3 166:11 167:23 186:24 194:17 195:11 206:19 213:2 213:19 228:20 229:14 231:20 231:24 232:23 234:4 242:3 257:16,17 265:17,18 266:16,22 276:10,11 277:23 ass 155:5,15 assert 180:19 asserted 70:16 170:3 180:18 Assessor's 86:18 Asset 109:16 assets 9:25 10:1 10:3 86:16 associated 16:15 associates 122:4 Association 115:23 116:1,1 131:11 assume 8:12 9:21 15:13,15 124:13 150:5 assuming 4:21 106:1 149:20 assure 129:7 attach 165:16 attached 73:25 77:14 78:18 93:25 110:17 attachments 77:19 79:21 86:8 attacks 142:20 attempt 55:25 142:25 144:23 149:21252:17 attempted 144:24 235:19 attempting 131:7 142:19 attendance 123:16 attended 5:21 6:22 7:5 226:6 226:23 attorney 27:14 44:11,12,13 49:13,20 84:24 89:20,21 119:1 142:24 143:25 144:2 149:19 173:25 174:2,6 190:9 191:14 192:19 193:21 200:21,24 239:21240:6 244:16,23,24 282:13,14 attorney's 159:2 208:18,20 240:2,18 266:8 275:20 attorney/client 20:1,3,5 134:18 173:22 attorneys 17:9 49:15 57:25 200:20 242:19 attributed 139:5 August 119:11 author 116:18 authority 173:8 authorized 77:3 282:8 available 228:8 avid 189:20,25 196:19,22 197:7,8,21,22 198:2 awaiting 156:17 award 259:1 aware 14:15 56:13 57:1 68:8,11,14,19 90:14 103:25 140:16,19,20 151:16,24 152:12 156:24 190:8,10 210:16 213:3 221:8 222:20 223:21225:3 226:16,16 232:15 246:10 246:16 247:24 248:1 Awareness 27:23 28:10,13 29:151:7 128:25 B B 79:17 106:7 baby 61:21 baby-sitter 240:7 baccalaureate 218:16 279:24 back 18:14 24:20 37:23 38:6 42:14 46:20 50:1,20 52:2,6,12 53:4 55:9 69:21 71:24 81:12,16 82:3,19,24 91:3 92:3,9,16 93:6,7 106:12 106:19,21,23 107:2,9,16 108:4 113:2 114:7 121:5 124:17 147:1,7 147:15 152:20 171:15 191:4 191:16 193:15 194:20 201:14 205:3,6 218:21 219:3 224:6 233:14,22 234:9 238:18 238:20 239:1 274:16 background 6:18 8:2 12:9 186:18,22,23 186:24 bad 208:23 badgering 276:4 badly 268:21 Baelz 277:7 Baez 181:11 218:20,25 219:3,15,18,22 277:2,6,21 278:12,14,17 278:20 bag 155:12 ball 99:25 balls 154:3 banks 137:18 banner 18:15,18 19:4 141:18 banners 19:12 19:16,18,23 141:8,11,14 142:6,21,25 143:18,19 144:1211:23 212:5 217:16 217:20 220:18 220:23 222:15 222:24 226:3 226:11,21 bar 19:5 56:10 56:11,15,16,20 57:2 58:9,13 58:15,16,19,20 69:21,23 70:7 70:15 74:2 75:15 78:8,10 85:10 86:5 89:17 90:15,16 109:12,24 110:2 111:5 114:23 115:8 115:10,23 116:1 119:18 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 9W 122:9,9 123:8 123:8,16 125:17,21 126:13,16,24 127:13,24 131:10 156:18 156:18 240:24 241:1,5 Barkdull 68:22 69:11 72:12,14 76:4 144:3 Barkdull's 76:10 barrage 265:20 barrages 266:1 barraging 264:10 based 37:25 74:11 90:3 99:19 110:8 112:21 117:4 118:15,16 128:2,7,8,9 129:14 168:6 218:23 253:21 258:24 260:6 265:13,18 272:9 274:13 basically 38:14 44:25 45:10 basis 10:20 37:15 58:22 65:23,25 68:4 68:6 77:10,21 81:6 82:9 83:6 83:16 85:1 150:23 249:21 254:25 279:9 bathrooms 189:13 BC 156:10 beach 2:4,12,13 19:3 86:18 177:4,12,13 198:4,6,14,14 198:15,17,18 199:3 200:6 201:21281:5 282:5 284:4,5 bear 114:2 273:4 Beatles 235:6 began 77:23 216:17,22 beginning 172:19 241:11 behalf 1:12 27:21,24 35:21 45:6 56:1,7 61:3,6,7 63:20 65:13 73:21 100:15 119:10 129:11 170:4 176:12 200:6 255:14 behave 128:7,8 behavior 21:19 33:5 122:8 123:8 163:5 237:24 238:13 belief 150:23 beliefs 162:21 believe 5:17 13:11,15,22 17:3,7,12 21:13 24:4 25:1,5 27:8 28:22 32:17 34:2136:18 37:21,22 38:5 44:3 45:11 46:14,22,25 47:13,21,21,22 51:2 52:1 53:25 55:24 56:6,9 57:7,20 63:17,18 67:4 73:14 76:2 77:6,14 78:7 79:7 81:3 82:12,12 86:1 87:10,13,13,14 87:16,23 88:1 88:14 115:4,7 117:13 119:17 119:22 121:8 121:22 122:18 122:20,22 130:14 141:16 142:17 143:9 144:6 146:24 147:6,23 148:21 150:20 151:20,24 156:21,23,24 156:25 157:3 157:22 158:2 161:19 162:9 162:18 163:1 174:18 181:14 183:15 188:12 200:7,22 202:10,10,23 206:1,19 209:7 209:8 211:15 213:2,22,24 214:2 217:5 223:12 225:11 226:22,24 227:24 229:11 233:16 235:17 236:10 239:4 239:22 243:13 244:13,18 252:5 255:15 255:22 258:7 258:22,22 259:2,7,8,10 259:11,20,21 260:4,8 261:13 266:5,20 272:21,22,25 273:17 believed 31:23 33:4 56:2 89:11251:13 bell 114:20 116:4 165:6 benefits 110:14 Berkeley 225:10 Berkley 11:7 best 31:15 38:22 39:6 72:21 76:25 149:10 149:12 152:8 168:20 170:4 184:23 200:12 202:3 227:2 230:2 233:3 better 38:19 48:22 72:13 75:10 115:14 245:8 beyond 84:6 121:15 160:20 182:5 208:20 250:3 268:5 big 36:4 38:14 54:19,22 158:9 158:24 198:3 198:13 260:11 269:18 biggest 64:4,12 65:1,7 73:6 bill 17:18,23,24 17:25,25 25:20 155:23 157:5 157:22 158:1,4 158:11,13,16 158:17,24 159:17,25 178:15 258:1,2 258:5 260:23 261:6,9,19,25 262:5,14 billed 21:23 22:2 22:4,6,10,12 22:15 26:15,17 26:22 157:23 158:6 262:11 billing 13:5,7,11 134:19 156:3,5 158:2,6 159:4 159:8,11,13,14 159:16,22 167:20 168:1 261:15 billings 16:14,14 22:15 23:23 24:5,9,13 134:17 135:12 155:22 157:25 bills 16:23,24 17:5,7 24:15 24:17,18,20,21 24:24 25:16 134:24 135:2 157:8 158:15 257:10,12,14 bit 23:2164:1 90:12 96:2 249:6 250:15 254:20 black 54:19,21 59:21 blamed 246:3 Blanc 144:4 blanket 99:23 Board 114:23 115:10 boards 221:12 boat 7:14,15,16 7:17 8:4,10,11 8:12,22,23,25 9:1,3,25 10:4 Bob 30:24 106:6 Boca 1:20 9:12 176:20 bodies 267:1 body 195:21 Bomber 157:12 bona 74:12 77:2 77:4,9 78:4 79:185:24 109:21258:22 272:19 book 54:21 books 54:20 bore 77:15 Boston 157:11 157:12 bother 182:17 233:22 bought 39:12 Boulevard 2:12 2:21 177:12,21 284:4 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 0 bourne 259:14 bowl 128:11,12 bowling 121:16 121:18 box 37:10,17,19 40:19 47:8 49:9,23,24 50:4,9 51:5,12 53:12,15 54:18 55:16 56:18 85:22 boy 184:17 271:14 branch 70:1,2 70:1173:21 74:7 77:2,5 78:4,25 110:5 branches 222:19 breach 57:2 break 28:5 41:25 42:4,7 44:14 45:17 59:9 71:22 72:8 108:15 112:23 113:2,10,16 115:14 131:24 170:6 171:11 218:7 242:6 254:10,11 Brenda 34:23 brief 17:1 147:22 226:12 bring 46:17 210:6,14 253:21277:18 bringing 265:24 Broad 111:15 brother 106:4 107:22 brought 45:16 210:16 213:3 buddy 152:23 budget 34:17 building 68:2 86:12 214:16 215:5 236:24 built 145:25 146:1 bullets 102:24 bullshit 168:10 bully 142:19,25 144:24 bun 184:24 185:1 bunch 100:12 248:4 249:11 burger 28:16 105:9 BURKE 2:20 177:20 business 34:18 34:22 46:7 158:22 160:3 201:4 269:2 270:22 busted 198:3,13 buy39:11 63:11 132:17 buying 132:15 C 106:7 111:3 C -A -F -I 32:1 Cafi 32:1 35:3 35:14,14,18,18 35:2136:12 37:2,18 38:4,9 38:12 40:4,9 40:10,12,21,23 41:9 43:18 45:12,13,19,20 46:2,11,17,21 47:11,15,15 48:16,16 49:5 49:6 50:18 51:3,6,13,16 51:19 55:16 63:2194:21 95:2,4 207:23 239:19 256:17 264:11265:20 265:21,21,22 265:23 266:14 273:16,19,22 274:1,2,24 calculating 219:2 calculation 218:24 call 15:9,11 16:9 46:17 91:2,2 92:16 94:19 106:6 121:2 131:12 146:15 149:16 157:19 182:9,10,18 183:3,8 190:16 190:19,20,21 190:22 212:12 239:5 244:20 249:1251:8 261:12 called 8:11,19 31:22 34:8 36:7,16 38:4 38:15 62:17 88:1 140:25 145:13 194:24 195:5 236:20 236:24 239:17 239:18,24 248:3 249:24 268:22 calling 5:19 237:22 244:4 249:21263:8 267:13 calls 127:25 133:3 168:18 272:5 276:13 276:17 cameras 132:18 campaign 216:24 217:5 222:8 campaigning 216:17,22 candid 188:3 capable 60:13 caption 215:22 card 46:14 146:16 cared 268:20 careful 33:10,12 carried 217:18 217:22 220:19 220:25 carriers 158:9 carry 116:16,22 carrying 217:25 221:4 case 1:3 5:3 7:24 12:13 13:10,13 13:13 25:22 27:8 30:7 36:12 40:20,24 57:5,8,13,18 74:4,11 77:6 85:14,23 91:4 95:7,14,16,18 96:2 105:7 109:19 110:12 110:19 128:11 129:19 138:20 142:3 148:11 150:18 151:19 151:20,21 153:6,7 159:24 160:16 162:6 168:2 176:3 184:14 214:3 229:21237:20 243:17 256:1,6 256:8,12,24 257:4 261:5,24 262:8 263:13 265:16,17 cases 13:14 15:21 16:6,19 17:16 18:2,7 18:11 19:11 25:24 29:25 30:1,3,5 34:12 36:8 45:23 62:18,25 84:1 119:23 168:3 211:17 234:23 235:13,20 237:21,25 270:15 273:16 274:22,22 caught 180:11 180:13 cause 197:4 235:15,23 cautioned 274:16 cc 284:21,22,22 cease 218:2 221:6 242:17 cell 77:22 78:15 Center 2:3 128:23 177:3 certain 53:13,14 53:19,21,23 62:18 65:20 91:12 100:7,13 102:19 certainly 4:20 7:25 42:16 60:3 90:3 96:20 105:6 128:10 161:20 172:13,21 206:15 214:8 254:12 261:23 261:23 271:4 CERTIFICATE 281:1282:1 certification 90:18 CERTIFIED 3:16 178:19 certify 12:19 20:16 29:3 44:15 123:3 201:6 209:23 281:9 282:7,12 chair 58:18 challenging 144:10 chambers 149:17 chance 248:7 273:3 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 5 Chandler 29:5 29:24 30:18,21 31:1,10,21,22 32:2,7,9 33:1 37:17 38:11,16 38:19,20 39:10 39:17 41:9 42:2143:15,18 44:2145:25 46:2,5,8,13 47:5,8,11 48:19 49:1,4 49:1150:11 51:9 52:4 53:7 53:12 59:4,12 59:17,21 61:24 65:11,15 67:10 70:17,19,20 72:1 124:22,25 131:22 160:14 160:18,23 163:3,7,11 207:22 239:5 239:14,17 243:19,21 245:1246:10 246:19,20 247:12,13,18 247:22 249:9 250:4 252:24 258:25 259:2,7 259:8,14 260:4 263:23 264:3 264:25 265:3 265:10,15 266:1,4 269:8 270:13,18 271:1272:9,20 274:3 Chandler's 40:3 51:18 55:15 240:13 247:25 250:11253:2 266:24 274:13 change 164:4 166:14 167:2 252:19 283:4 changed 166:8 166:12 167:1 changes 254:7 changing 155:19 155:21 Chapter 163:9 227:22 character 115:20,20,22 115:25 characterization 167:6,10 characterize 154:5 characterized 54:11 charge 35:22 charged 75:11 75:13 211:22 212:5 224:22 charging 73:17 chat 237:15 check 115:15 218:25 266:15 checks 266:16 children 223:9 children's 225:7 chill 233:10 China 146:15 choose 129:14 238:1,1239:5 chosen 44:11 Chris 245:7 246:11264:21 264:22 Chris' 264:23 chronology 50:12,15 CIA 32:10 circle 242:9 Circuit 134:10 134:13 151:21 193:21,25 200:15,16 213:6 cite 76:1 cited 74:4 77:6 85:5,14,23 86:7 109:19 110:13 196:11 Cities 262:23 Citizens 27:23 28:10,13 29:1 51:6 128:24 city 21:9 96:6 97:11235:7 246:13 civil 100:4 203:5 claim 10:22 13:23 14:2,13 14:15,18 37:20 43:19 45:13 66:19 72:17 168:10 258:7 258:23 273:16 claimed 104:17 claiming 16:16 40:22 96:22,23 154:17 168:17 169:3,12,20 170:2 claims 15:2 63:1 63:2 66:4 266:19 clarify 67:24 class 156:10 classes 225:7 classic 265:23 clean 174:16 180:23 clear 71:1 195:16 258:15 265:6 268:6,7 268:7 271:15 clearly 143:3 clerk 149:18 155:24 156:1,3 156:4,8 157:10 157:14,14 client 8:4 14:6,7 14:14 20:7 21:3,12,17,22 37:156:7,11 66:4 71:11 75:21 117:23 120:19 121:14 122:6 128:3 133:8,15,17 139:12 140:8 140:23 153:3,4 159:17 164:3 166:7,10,18,19 167:8 228:25 238:3 241:7 245:4 267:9,12 270:12 client's 97:7 120:18 238:21 276:8,10 284:10 clients 12:5 16:6 16:7,19 17:16 18:12 87:7 121:13 128:9 168:1267:12 270:11 close 34:21 211:15 216:11 233:3 closely 64:7 closer 124:8 closing 274:24 club 121:24,25 223:2,8 clubs 121:20 223:4 clue 36:1 co -counsel 75:7 122:4 coach 256:14 Coastal 21:5 code 189:10 217:24 221:3 COLE 2:11 177:11284:4 Colgate 7:5 collect 258:16 262:13 collected 266:9 273:24 collecting 261:15 261:17 Collector 86:18 college 7:3 8:18 105:21,23,25 106:1,3,8 107:5,6,13,18 107:25 108:7 108:23 109:1 colloquy 69:18 come 31:20 45:5 46:20 85:15,19 113:2 148:25 167:16 182:8 182:12 187:23 229:20 237:19 267:2 comedy 196:10 comes 63:3 197:25 219:21 comfortable 21:2,7,8,11,13 21:18,2122:18 24:2 25:12,15 28:23 29:20 30:13 40:18 41:144:6 49:20 50:24 55:5 60:17 86:15 96:15 97:5 117:17 166:9 comics 185:4 coming 199:4,5 251:22 comment 52:4 139:18 154:20 155:3,10,13,16 155:19 184:24 233:12 commentary 48:13 83:1 94:14 231:11 231:15 239:3 245:22 271:19 comments 138:25 139:6,8 139:21,24 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 I 149:23 153:8 153:14 154:22 168:14 Commerce 34:1135:9,14 35:15 207:23 commercial 23:21 158:9 commission 149:17,17 166:24 202:11 246:17 247:3 259:25 260:6 281:22,23 commissioners 21:15 214:15 215:1226:4 commitment 168:2 committed 31:24 159:24 Committee 58:19 115:21 115:22 committees 197:13 communicated 87:18,19 102:2 103:23 104:5 communication 20:4 33:22 90:22,25 92:21 92:22,22,23 133:4,13,19 170:12 212:3 247:18 276:11 communications 20:2 21:12,17 25:13 36:6 47:16 91:10,11 92:25 119:5 128:3,9 131:3 139:12 140:22 166:10 167:7 170:24 224:5 240:21243:9 243:11,12 245:4 247:12 274:15 276:8 companies 38:13 company 80:25 85:25 144:19 201:3 255:17 257:1 compared 203:5 competently 238:3 complaint 3:12 56:11 89:24 90:1,2 127:12 179:4 186:5 211:9,11 231:23,23 266:18 269:19 complaints 46:5 127:6 complete 258:23 260:7 completed 72:8 284:14 completely 12:12,20 66:18 complex 45:9 compliant 174:14 complied 210:4 210:9,21,22,24 computer 15:6 26:20 28:21 50:8,8,14 54:25 59:9 conceivable 193:13 concept76:8 157:15 concern 197:14 concerned 75:17 100:8 127:3 257:24 concerning 10:8 126:16 128:24 136:22 189:10 220:21253:17 259:19 concerns 88:2 227:12,19 conclude 267:15 267:16,17 concluded 182:13 204:16 234:7 280:10 conclusion 17:11 31:4 43:23 51:4 97:24 120:4,7,11 123:17,25 131:14 133:20 156:21 157:2,4 164:17,20 165:20 168:18 170:18,19 175:7 185:25 207:25 210:9 210:12 214:23 226:11228:2 228:10,17 229:8 244:5,20 267:2 272:5 conclusions 123:20,21 165:3 197:4 conclusively 216:25 265:18 conditional 71:16,19 conditions 74:8 condo 81:5 conduct 31:24 55:15,15,22 56:2,13,13 91:5 137:3,8 137:19,20,25 138:2,3,8 142:8,23 150:18 160:23 168:7 197:10 197:11221:22 222:10 239:7 241:6 248:13 248:16 251:15 252:20 253:2,6 264:19 267:14 271:7 272:19 272:20 conference 116:6 130:20 262:15 conferences 131:5 confidence 224:12 confidences 17:17 confidential 40:22 45:13 47:5 115:7,11 116:13 117:15 118:4,9,13 121:23 130:16 130:18,22 131:4 147:6,9 152:18 170:14 201:4 202:19 confidentiality 134:6 confidentially 153:25 confirm 98:16 115:15,15 124:14 confirmed 21:6 conflicting 59:18 confrontation 68:22 69:10 confronted 36:17 132:14 confused 260:2 confusing 262:22 Congressional 143:12 connected 282:14 connection 4:21 5:18 15:25 19:8 27:16 37:12 55:14,15 56:17 60:25 62:18 73:4,8 108:14 168:16 199:25 213:13 228:9 246:13 251:4 255:17 255:25 263:7 274:8 connotation 272:3,6 consider 91:4 154:20,22 155:1227:25 236:3 263:14 263:20 consideration 39:11 considered 200:22,23 270:6 considering 243:16,22 consistent 144:23 conspiracy 124:22,25 constitute 124:25 constitutes 69:12 85:2 124:22 constitution 193:4,6 203:2 constitutional 189:22 190:5 191:8 202:23 203:3 227:5,9 269:1 constitutionally 214:11,21 217:16 220:8 220:17,22 225:24 242:12 242:18 construction 189:3,15 consultation 244:12 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 7 consumed 160:1 contact 20:20 87:20 182:1 183:25 contacted 49:17 163:3 contacting 49:18 160:18 contained 211:22 212:4 contend 227:17 contends 227:10 content 31:11 58:24 59:11 60:11 103:8 104:15 121:22 131:11217:4 217:10 contents 40:18 118:22 context 5:7 96:24 99:8 103:18 203:17 248:15 contingency 274:19 continue 41:22 159:25 233:17 277:12 continued 222:15 Continuing 178:5 contractor228:1 228:25 229:6 contractors 244:2 contradicted 259:15 260:9 contrary 110:8 convenience 19:10 conversation 32:5 47:14 102:11 150:14 conversations 190:2 copies 24:15,16 24:18 copy 15:8 31:18 67:6 76:25 79:22 84:17 94:2 99:20 117:12 130:2 141:2 152:2 174:13,16 179:24 180:3 180:23 252:12 260:18 284:12 Coral 1:25 176:25 281:19 282:22 284:20 corporation 33:14 70:10 83:12 186:13 corral94:19 251:5 correct 8:22,25 11:4,8 14:9,11 41:8,12 45:25 47:12,23 54:16 56:2161:1,11 62:20 65:16,18 76:16 94:23 95:10 123:10 124:14 134:23 141:24 143:8 145:7 149:13 151:7 165:13 165:17 170:17 171:21 172:1,2 172:9 202:14 213:13 215:17 234:16 236:2 246:21257:2,5 261:18 Correction 283:4 correctly 81:5 88:5 correlates 77:23 correspondence 91:9 93:11 104:9 273:24 corroborate 143:15 corroborated 271:2 costing 257:25 counci125:2,11 25:13 90:17 148:25 149:3,5 216:16,20 259:24 262:23 counsel4:18,20 12:16 19:24 20:23 21:4 26:4 49:6 50:18 71:13,17 80:7 119:9,25 122:16 125:12 133:3 139:13 142:12,20 149:14,15 151:3,8 152:24 152:25 168:20 168:23,25 185:6 212:16 213:12,16,18 213:20,25 214:3 228:13 236:11256:1 257:8 262:25 282:13,14 Counselor 10:11 count 61:18 63:17 185:9,10 204:16 225:14 counted 54:2,13 106:12 203:23 counter 62:25 counterclaim 27:10,11,13,15 27:16,23 28:2 57:4,11,15,16 57:17 63:12,13 63:16 counterclaims 27:21 country 85:18 147:25 County266:20 273:13,15 274:11275:20 281:5 282:5 couple 19:3 52:18 74:15 126:20 course 13:13 37:10 51:4 94:4 103:10 112:3 192:21 240:15 court 1:1 12:18 13:22 14:1 20:1128:4 31:16 38:3 40:24 43:10 52:16,25 53:5 60:25 63:20 67:4,25 68:3 72:4 74:5 81:14 92:2 99:21 110:13 113:20,22 114:13,15,24 121:2 123:4 132:24 142:2 142:18 143:25 151:11 152:9 157:16 171:11 171:17 174:8 174:25 175:6 176:1 179:3,8 200:15,18 201:19 205:5 208:17 214:18 215:17,24 218:7 233:20 235:7 241:10 241:15 243:22 251:10,13 252:2 253:18 254:10 260:14 266:20 273:11 273:17,18 277:19 278:2,4 279:3,14,18 281:8 282:7 284:18 Court's 12:14 14:4,23 courtesy 159:16 277:8 courthouse 236:24 courts 75:15 142:15 cover265:15 coverup 260:10 260:12 CPA 156:11,17 create 232:1 credibility 36:10 60:1 credit 46:14 262:4,7,12 crime 38:1 274:11 criminal21:19 31:24 32:19 33:4 56:2 160:24 161:10 161:11,12,15 162:24 163:5,9 237:23 238:12 239:6,15,18 241:6 248:11 249:1,11,24 272:3,6,22 criminals 248:4 249:12,22 critical 211:23 212:5 217:17 217:20 220:18 220:24 226:3 226:21242:13 criticism 226:8 criticize 222:15 criticized 227:1 criticizing 214:14,25 222:23 cross 199:3,11 199:18 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 I crossed 199:12 199:20 crush 160:9 curious 98:10 current 234:21 253:21 currently 14:14 30:199:18 101:3,5,8,21 138:20 211:13 cuss 64:25 D Daddy 36:4 38:15 Dade 266:20 273:13,15 274:11275:20 daily 217:25 221:4 damage 189:4 189:10 data 253:17 date 1:16 60:21 96:10 101:10 116:3,5 176:16 211:5,5,6,7,7,8 211:10,12 dated 42:3 282:16 dates 80:23 271:11 daughter 135:23 135:23 218:17 224:15,15 daughter's 11:4 279:24 daughters 1:18 1:23 11:5 176:18,23 224:16 281:17 282:21284:13 284:19 daughtersrepo... 284:14 David 11:11 16:15 135:14 146:4,5,5,20 day 33:18 35:7 39:25 116:16 116:22 197:24 198:1217:25 218:1221:5 233:1251:17 253:14 281:11 281:13 282:16 283:23 days 75:6 deaf 246:22 dealing 74:5 166:21 167:13 dealings 51:25 dealt 82:21 215:24 249:22 Dear 284:9 death 108:19 debate 17:12 24:10 debated 163:13 272:15 debating 272:13 decal 181:2,6 decide 38:3 254:1262:13 266:24 decided 109:24 233:4 270:8 decision 86:3 182:16 208:17 208:18 244:9 244:11,25 247:5 254:20 declaratory 63:17 deduct 23:13,13 deductible 255:12 256:2,5 256:17,23 deductions 34:7 deem 17:10 25:3 deemed 236:18 Deerfield 2:4 177:4 198:4,14 198:15,17 200:2,4,6,8,11 201:10 defamation 110:22 defend 235:19 Defendant 2:8 2:17 14:11,12 36:12 95:7 177:8,17 186:12 214:1 257:4 261:24 262:9,10 263:13 Defendant's 76:16 83:10 Defendant/Pla... 235:13 Defendants 1:9 27:6 176:9 186:6 212:14 213:18,20 defending 18:7 235:18 237:21 262:14,16,16 defense 5:3 158:4,5,8 defenses 169:9 169:23 170:3 defraud 163:8 243:18 252:6 265:19 267:4 267:16 272:10 272:17 degree 7:7,10 delighted 73:3 delivered 17:7 Delray 121:20 191:18 223:7 delve 12:10 demand 49:25 274:17 demanded 36:13 266:21 demanding 37:22 71:7 266:18 DeMartini 34:24 36:25 demise 264:20 demolished 189:3 denied 266:20 Denise 34:24 36:25 denounce 202:16 deny 64:19,21 144:8 denying 64:22 74:21,23 75:1 75:2 144:7 214:15 215:5 depend 131:18 228:18 depends 39:25 157:17 158:3 159:5 170:18 depo 278:3 depose 271:4,12 271:12 deposed 277:22 deposing 256:25 deposition 1:11 3:3 4:9 39:22 64:3,9 80:6 110:23 125:20 126:2,24 164:7 164:8,9 165:1 165:11,12 171:20 172:20 174:24 175:7 176:11 178:3 182:3,13 183:22 211:25 215:8 232:17 232:22 247:25 249:16 266:10 274:4 279:21 280:9,10 282:8 284:6,11 depositions 148:19 183:20 237:16 248:9 derogative 223:25 derogatory 139:5,8,16,18 139:20,24 149:23 150:11 152:20 153:8 153:14 154:2,2 154:6,12,20,22 155:2,3,7,10 155:12,15,19 describe 154:11 269:1 described 19:22 33:13 38:21 46:25 227:5,11 234:18,25 243:19 272:20 274:21 describing 45:1 207:22 272:9 description 274:13,15 deserved 270:23 designation 90:16 designed 142:11 235:15 desire 26:2 46:9 237:16,18 despite 266:1 destroy 265:11 DeSusa 40:20 details 16:20 253:7 determination 250:25 determine 118:8 137:2,7 determines 159:13 determining 138:2 detractor 196:24 197:22 detrimental 254:7 DeVargus Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 E 135:16 develop 34:18 160:15 264:7 developed 167:14 difference 58:14 84:9 146:12 208:22,24 258:15 differences 131:5 different 21:3 49:9 51:10 110:19 126:20 137:25 151:21 155:6 157:15 166:25 167:11 167:12 169:2 251:1 differently 75:18 117:4 difficult 45:3 diligence 90:12 dimension 239:11 dinger 248:18 dinner 276:19 276:24 279:22 dire 101:11 direct 3:5 4:6 63:8 178:6 directed 35:21 56:3 79:14 directly 75:14 77:6 243:12 director 114:23 275:8 directors 34:25 disagree 13:21 277:25 278:1 278:15,18 disagreeing 278:23 disagreement 278:22 disagrees 278:12 discharge 238:3 disclose 15:20 17:15,19 18:10 20:121:16,20 44:5 86:15 93:22 117:22 118:21 140:8 154:8 170:12 194:12,13,17 204:20 240:20 243:8 245:3 247:11,16,21 disclosed 121:22 164:1,5 165:12 disclosing 21:2 24:2 194:15 263:23 discount 89:18 discounted 159:16 discovery 14:23 18:6 25:23 212:19,22 discuss 4:14,25 5:2 8:16 9:23 10:1,5 12:2 17:13,16 32:25 69:19 91:2 121:12 134:20 139:11 140:23 162:20 170:13 180:1239:23 272:18,24 276:8 discussed 10:6 38:24 121:13 121:14 130:21 131:6 151:9 163:10 165:1 166:7,24 181:13 239:24 257:6 272:16 discusses 241:6 discussing 18:1 21:1125:12,15 31:8,9 37:1 40:18 44:6 163:10 166:9 discussion 33:3 33:10 45:23 47:9 49:11 117:16 121:23 172:16 174:10 201:21241:12 discussions 4:18 4:20 8:16 21:3 24:3 33:11 37:16 44:22 163:2 166:18 166:19 233:8 239:20 272:7 disgust 265:4 disgusting 264:24,25 dismiss 14:4 235:16,24 dismissed 13:22 14:1 displayed 217:3 217:10 226:2 226:11 displaying 217:17 220:18 220:23 226:18 dispute 214:17 215:14 disputing 238:7 238:8 274:1 disqualify 65:8 65:13 67:18 73:14 74:10 76:16 79:4 83:10 111:4 142:10 236:17 237:3 disregarded 91:16 disruptive 184:9 234:2 District 1:1,1 176:1,1 186:14 diverted 201:10 234:10 divulge 104:23 224:4 document 37:14 41:2,6 43:20 44:19 50:14 57:24 58:5 59:1160:6 64:2,6,10 73:5 73:8,9,12,17 75:14 76:15,22 80:23 83:18 85:3 98:2,3,14 98:15,18,20 99:8,12,18 100:18,19 101:11 111:3 117:6,8,9,11 127:3,15 129:9 130:3,6,8,16 130:19,23 131:1,13 181:3 201:10 228:12 260:22 documentation 63:4 146:22 147:3 documents 38:3 38:6 41:4 45:2 45:13,16 47:2 47:6,16,22 48:15,16,20 49:4,5,9 50:1,4 50:5,24 51:5 51:12 53:13,14 53:15 54:13,25 55:16 56:18 60:24 62:1 63:2177:14 79:23 93:24 105:22 106:8 108:6 117:3 151:10 152:5,9 152:14 188:16 268:21 Dog 8:11,14,19 doing 6:12 19:10 21:8,18 28:5 30:13 36:2 39:21,25 55:1 55:5 75:20 100:21 113:17 129:15 144:11 144:12,25 145:1 150:9 154:1 167:24 181:8 183:21 185:19 198:1 201:15 230:22 233:7 263:24 264:24 266:13 dollar 156:13 dollars 22:4,6 domicile 107:19 domiciled 98:8 101:3,6,9,13 187:23 door 224:11 doubt 143:17 doubted 49:1 douche 155:12 Downstairs 132:12 dozens 18:7,7 144:23 197:23 197:23 DPV 135:12 Dragnet 67:16 drink 242:5 Drive 1:24 2:3 111:6 176:24 177:3 188:10 281:18 282:21 284:19 driver's 107:21 drop 37:10,17 37:19 40:19 47:8 49:9,23 49:24 50:4,9 51:5,12 53:12 53:15 55:16 56:17 243:1,4 due 90:12 230:25 231:1 242:14,21 duly 4:3 281:11 duties 166:2,6,7 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 10 166:8,12,14,17 166:22,23 duty 56:6,9,14 57:3 115:19 123:15 238:3 241:8 E E 1:4 2:2 176:4 177:2 186:4,5 284:7 e-mail45:11,18 46:25 246:11 247:2 e-mails 36:6,21 36:23 46:1 50:15,17 51:2 51:15 274:15 E -X -H -I -B -I-... 3:10 178:13 ear256:21 earful37:7 earlier25:1 88:20 122:7 130:9,11 149:22 ears 246:22 easier 63:8 99:23 100:17 186:10 east2:21 102:12 103:14 177:21 251:15 eat 128:12 eating 113:18 education 6:21 effectiveness 222:18 effort 20:21 184:1 eight 11:22 188:8 eight -foot 68:1 either 51:5 62:12 66:1175:14 88:197:12 129:20 183:7 228:7 229:19 240:7 262:23 276:23 elaborating 260:5 Elaine 105:9 election 222:14 222:24 elections 222:23 electronically 58:6 74:19 75:5 element 153:15 Eleven 210:25 211:1 email284:13 emanated 117:8 250:19 emblem 199:17 employed 16:12 employee 259:4 282:13,13 employees 12:11 153:4 154:13 employment 51:19 enclosed 127:8 encourages 131:4 endeavored 235:13,17 enemy 136:20 enforce 194:25 210:6,15,17 215:10 227:9 234:19 235:1 enforceable 192:4 enforcement 192:20 217:24 221:4 240:21 276:9 enforces 194:23 engage 10:20 214:20,20 235:14 engaged 35:12 72:18 76:20 77:21 83:14 88:8 89:8,21 112:1 137:19 137:20 142:9 163:4 197:18 211:13 217:15 220:8,17 239:14 engagements 12:21 engages 214:10 engaging 220:21 Enquirer 204:18 ensure 222:17 entered 14:5 153:6 256:9,11 256:16 entire 34:6 42:5 52:21 entirely 170:25 entitled 75:22 79:17 120:14 entity 31:25 35:4 38:4 45:6 46:22 86:19,24 198:12,16 207:21213:4 253:13 equipment 28:20 252:13 erase 247:8 errata 283:1 284:13,14 Esq 284:21,22 284:22 Esquire 2:10,19 177:10,19 284:3 essentially 35:4 102:23 establish 83:12 established 210:12 estimating 11:21 estimation 278:10 ethical 55:23 56:12 89:13,13 89:24 90:1 ethically 55:17 238:2 ethics 90:13,17 evening 230:4 265:1 event 19:6 227:1 events 225:3 226:7 evert 193:13 everybody 185:1 evidence 40:16 69:24,25 70:4 78:12,14 89:12 89:16,19,23 90:2 101:2,7,8 104:16,24,24 105:1,2 109:21 110:9 138:11 138:13 139:2 171:4 196:20 249:19 250:20 250:23,24 266:19 269:7 evidentiary 76:18 exact 18:25 88:17 149:25 249:12 252:10 exactly 42:11 52:7 62:14 98:17 124:4 180:10 exaggeration 41:17,19 Examination 1:22 3:5 4:6 176:22 178:6 Examiners 114:23 115:10 example 12:24 16:25 88:21 105:24 187:15 214:12 229:9 252:23 264:10 270:19 examples 225:23 exceed 217:25 221:4 excerpt 52:17,19 52:22 93:16,16 201:20,22 241:11267:21 267:25 280:5 excess 49:15 266:17 excessive 207:3 207:13 exchange 92:24 93:1 147:22 exclude 66:1 excuse 33:24 53:20 60:8 70:19 110:18 150:5 executive 222:19 275:7,8 exercise 89:13 189:21 191:8 193:4 225:24 exercised 210:5 210:13 exercising 190:4 exhausted 256:3 exhibit 111:3 112:4 174:21 181:7 233:15 260:15 263:18 267:23,25 280:7 exhibits 78:18 266:25 existed 45:8 existing 192:4 expand 193:3 expansive 193:11 expect 71:15 157:5 168:3 230:4,5,6 258:25 expectation 257:21 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 11 expected 160:2,2 160:8,15,20 167:25 expecting 71:19 257:14,17 expenses 23:3,4 23:6,13,14 experience 57:1 90:15,20 158:21 expired 256:3 expires281:22 explain 5:14 146:12 275:21 explained 45:7 88:20 251:13 275:21 Explaining 21:9 explanations 16:15 Express 146:16 expressed 97:18 97:20 expressing 227:19 extended 232:22 external 153:4,5 extinguished 256:18 extortionist 161:18 162:9 F facade 214:13,24 215:2,7 face 239:2 fact 5:13 6:4,5,8 31:9 65:20 67:21,24,25 68:2 72:1,3 76:12,13 78:13 82:13,14 84:18 85:5,8 104:17 129:8 151:18 222:21237:12 239:23,24 251:11271:1 factor 105:5 factors 78:16 228:18,22 229:1 facts 5:12,17 7:23 66:23 67:4,7,8,9,16 67:17,19 68:8 68:10,11,14,19 69:10 70:16,21 72:11,14 73:12 73:19 74:8 76:1,5 78:6 84:12 89:23 103:25 117:5 137:8 167:14 167:16,18 207:19 237:19 238:1250:4,12 268:4,11 272:24 273:1 factual40:16 65:23,25 68:4 68:6 70:20,21 73:8 77:10,21 81:6 82:8 83:6 83:16 85:1 143:18,24 196:20 fair 164:11,14 222:2 fairness 131:10 faith 60:2 76:2 fallen 246:2 false 179:13,14 185:19,19,20 185:20 206:20 243:23 271:2,8 271:8 familiar 4:12 58:9,13,14,15 58:20 95:8 114:25 115:1 191:3 208:16 212:8 227:21 family 9:22 10:7 12:1181:4 103:16,20 146:19 224:17 224:20 242:15 242:22 far 18:121:23 75:17 113:17 143:17 153:1 166:25 188:13 farm 45:11 farmed 45:23 fashion 40:25 133:7 fashioned 54:25 fashions 252:19 faster 100:24 father 270:12 father's 84:24 fatty 267:17 favor 126:18 fax 15:10,12 251:19 252:11 FBI32:2,8 275:21 February 216:15 216:19 217:19 220:23 federal 1:19 27:8 100:3 157:11 157:16 176:19 193:6 214:18 215:17,24 222:11 234:19 235:2 fee 259:1 274:19 feel 50:23 115:14 166:9 249:24 250:2,3 251:7 268:21,24 feeling 268:14 268:15,15 fees 36:14 45:6 75:22 79:17 167:19 208:19 208:20 258:12 258:16,16,23 262:13,14 266:8,19 273:17 fellas 157:21 fellow 136:11 173:12 260:11 felony 47:24 79:10 fend 120:1 FF 281:23 fide 74:12 77:2,4 77:9 78:4 79:1 85:24 109:21 258:23 fides 272:19 field 166:25 221:23 fifteen 222:4,6,7 225:12 fifth 224:14 225:11241:15 fifty 53:24 190:22,24 fights 137:17 figure 113:15 201:16 234:9 figured 254:5 file 13:1,4 27:10 27:13,14 33:19 46:20 60:2 93:10 134:12 151:25 161:22 195:4 215:9,9 229:10 243:5 253:23 254:2 filed 19:8 27:1,3 27:20,22 35:13 35:20 36:10 40:2156:11 57:4,8,12,18 57:19,20 58:6 60:20,21,24,24 62:4,16 63:12 65:12 66:14,18 67:3,1173:5 74:9,19 75:5 75:14 76:2 86:8 87:23 88:4 127:7 134:9 142:10 151:19,22 152:1,3,6,7 161:25 168:20 202:9,10 211:1 211:8,9,18 222:10 227:6,8 227:9 234:21 246:4 258:6 264:12 269:19 274:5 filer 244:14 files 15:19 101:16 148:10 234:6 264:18 filing 61:22,22 63:7 87:22 168:10 197:23 227:16 251:14 264:8 266:17 274:22 filings 19:11 60:10,25 61:7 61:10,14,17,18 62:17 63:4,5 68:9,20 70:5 108:22 Finally 180:11 financial 23:2,19 23:20,22,24,25 24:3 86:14 247:15 265:13 financially 264:16 282:14 find 13:10 73:15 90:12 92:10 110:24 136:24 137:6,8,14,16 138:9 142:5 147:24 148:4,6 166:6 182:14 194:10,11,14 248:12 249:22 277:9 fine 5:4 6:15 27:12 49:21 70:25 83:8 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 12 128:15 152:16 165:24 185:12 186:12 187:3 194:20 202:21 208:2 217:12 252:9 278:21 279:8 fines 217:25 221:4 finish 28:5 34:3 69:171:20 108:18 112:25 182:3 finished 219:7 248:1 firm 11:17,19,25 12:3,5,6,11 16:9,13 18:9 23:23 24:24 27:22,24 31:25 33:19 34:16,17 35:6,10,25 36:14,18 37:1 37:4 38:6,12 40:22 45:22,24 46:2,17,20 57:20,2158:2 65:8,14 67:2 69:25 70:3,12 73:14 74:7,10 74:12 75:22 76:17,19 77:2 77:3,5,9 78:2,3 78:5,25 79:4 79:14,15,16,17 80:18,20 85:12 85:25 86:3,6 87:6,25 95:4 95:18 109:22 109:23 110:4,6 112:1 119:20 120:11 127:8 128:24 142:10 142:19 155:23 156:11 158:3 158:12 161:25 168:5 213:24 213:25 214:2,3 227:25 228:8 228:14,24 230:4 236:17 237:3 244:13 244:14 256:6 257:9 262:18 262:24 263:6,7 266:7,14 267:6 267:8,9,11 270:8,16 274:16,21,24 firm's 24:1,2,22 24:22 159:17 firms 158:9,10 158:10,24 first4:3 13:18 14:17 38:8 40:2 47:18 49:18 59:24 69:2173:13 84:2196:23 140:7,16 141:19 142:15 157:13 167:3 186:18,25 187:1,6 195:8 204:7 215:9,10 226:10 236:5 244:4 248:8 249:17 268:8 firsthand 137:21 137:23,24 212:1 fit 112:4,7 115:17 192:23 251:7 Fitness 115:20 115:22 116:1 five 18:22 95:22 170:6 187:10 187:20,21 266:18 Floor 2:12 177:12 284:4 Florida 1:1,20 1:25 2:4,13,22 6:23 7:11 57:2 58:19 69:23,25 70:6 73:21 74:5,6 78:3,13 79:1 83:13 84:25 85:10,20 86:2,3 89:18 90:10,11 107:19 108:1,9 109:13 110:1,5 111:6 114:22 119:18 126:4 127:13 128:23 135:18 163:8 176:1,20,25 177:4,13,22 186:14,14 188:10 189:21 191:6 192:3,13 192:14,22 193:2,8 194:22 194:25 195:2,6 195:13,20 196:3,7 197:8 197:10,18 200:18 203:5 210:5,14 211:19 227:22 270:7 272:10 272:12 281:4,9 281:19,22 282:4,22 284:5 284:20 Florida's 190:1 196:20,23 197:7 flown 226:2 flying 18:16 141:9,15,18 142:21 144:1 217:16 220:17 220:23 226:17 focus 160:5 187:20 follow 55:13 201:17 following 20:14 28:8 42:13 52:12 72:6 81:20 82:6 83:3 92:6,13 103:11 107:2,9 107:16 108:4 113:24 114:6 121:5 127:8 132:22 171:14 174:11 179:1 218:14 233:24 254:14 279:17 follows 4:4 186:8 fool 155:5 force235:12 forego 235:13,18 foregoing 282:9 forget 102:8 132:19 189:6 249:12 forgetting 109:3 forgot45:8 fork 128:12,16 form 5:9,20,25 14:13 16:17 19:1,17 22:8 22:17 24:23 30:19 43:21 47:7 48:2,18 48:24 49:7 50:19 55:19 57:6 58:17 59:6,13 60:12 61:2,12 62:3 62:22 63:14 67:20 69:14 72:15 73:11 77:24 79:11 80:2181:10 82:25 83:19 85:3 87:19,21 88:10 89:10 91:6,17 94:25 95:11,25 96:12 97:15 98:13 102:14 105:16 106:10 109:5 109:15 111:10 111:17 112:8 112:14 115:24 116:20 117:20 119:3 120:2,9 120:20 122:10 123:18 124:23 125:22 126:12 126:25 127:14 129:4 130:4,13 131:15 134:11 136:25 137:9 138:12 139:10 139:22 141:12 141:21,25 142:7 143:20 146:9 148:2 149:9 152:11 153:19 154:7 154:18 155:4 160:12 161:5 162:12,19 164:13 165:7 166:16 167:4 169:4 170:10 170:22 179:17 187:17 192:6 192:10 195:23 198:8 199:8 202:2 204:19 205:19 206:5 207:14 209:1 213:14 223:5 223:13 224:23 228:16 229:13 231:10 236:6 237:1,13 240:11243:7 244:3 245:2,10 246:15,23 247:4,9 248:5 249:2 250:9,21 251:9,11,16,25 253:4 257:18 258:4 260:13 261:11263:17 263:21270:2 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 13 272:4 275:5 276:14 formed 45:12,19 45:20 46:2 former 32:2 200:15,17 202:12 forms 35:15 214:10,21 Fort 2:22 6:22 177:22 forth 47:17 56:18 67:3,4 68:9 78:1 98:18 106:2 109:16 130:10 179:21,23 240:9 249:16 251:6 274:16 forward 124:12 124:13 127:23 127:24 131:9 243:17 247:6 forwarding 127:10 Foster 244:14 262:24 found 62:7 138:14 148:5,5 273:17 Foundation 27:23 29:1 128:25 Foundations 51:7 four 41:14 125:19 127:9 147:19 221:10 Fourteen 217:13 fourth 241:14 frankly 160:6 fraud 38:1 243:22 fraudulent 31:24 33:5 56:2 163:5 237:23 239:7,19 French 58:20 Friday 1:16 176:16 232:22 friends 8:17 223:22 front 28:20 37:2 39:4 144:3,4 189:5 205:13 234:8 236:13 fucked 155:10 fu1147:4 159:22 269:7 full-time 35:8 70:6 86:4 279:7 fully 14:15 142:12 function 157:25 158:11 166:17 fund 246:2 262:6 funded 34:10 funding 33:13 34:6,17 38:9 38:1140:4,8 40:10,12 41:9 43:18 funny 225:18 further 90:4 282:12 furtherance 127:6,11 future 60:10,14 230:22 231:2,3 231:5,21 233:12 234:4 276:11 G -A -V -A -G -N -I 114:20 126:21 gaining 110:24 game 164:11,14 garage 28:16 Gavagni 114:19 114:22 125:17 126:17 127:23 129:2 general 18:24 23:16,25 56:25 80:24 151:2,2 155:3 246:1 generally 19:2 33:9 58:11,13 58:15 67:8 83:14 88:7 94:18 97:7 135:20 147:16 156:8 generate 34:12 34:15 253:24 270:15,21 generating 33:17 genuine 77:5 geographic 187:13 getting 156:18 165:4 212:25 225:13 242:4 249:3,4 268:5 give 5:10,14 6:18 7:25 12:8 28:25 30:11 35:24 37:19 39:4 43:22 47:3,25 48:8 56:25 67:9 71:7,8,12,14 76:25 79:24 86:10 96:19 97:8 99:12 100:20 105:24 106:3,4 107:23 107:24 111:9 112:18,19,20 114:4 116:23 120:7,8,12 123:19 125:4 126:8 128:6 133:21,21,22 133:23 137:1 142:1 145:19 161:3,4 168:20 172:11 179:3 180:3,24 183:6 184:23 192:9 194:3,6 195:10 195:12 196:2 196:12 202:25 207:4,9,11,18 208:1,2,7 209:3,14 218:5 218:17 228:10 228:19 229:16 229:17 240:14 241:2 248:23 250:6,7,13 252:4 253:1,6 253:7 256:22 262:4,6,12 279:1,4 given 8:17 3 9: 10 69:7 91:25 266:21 giving 14:24 17:14 28:23 29:20 39:5 69:16 76:7 96:15 110:14 203:6 glad 84:15 143:2 238:8 glance 55:7 glass 138:10,13 139:2 168:9 171:3 250:20 250:23 go 16:20 31:17 37:5,9 42:5,9 42:10,14 44:18 45:10 46:8,19 50:11,20 80:1 80:3,8 81:16 92:3,9 93:14 100:17,24 106:16,17 108:18 115:16 121:15,15,16 132:2 147:1,7 147:15,20 174:8 179:11 183:22 184:5 185:10,11,13 189:13 191:4 194:10,20,21 195:4 201:2 203:11209:25 218:21219:3 220:2,3 221:7 222:25 224:10 225:13 231:24 233:14,22 234:9 235:9,25 240:2,18 243:17 244:25 245:13,17 246:7 247:6 253:10 254:16 255:7 256:22 264:6 267:9,10 267:10,11 270:14 272:21 275:19 279:14 279:22,23 goal252:10 266:11 goals 197:1 goes 113:18 185:25 193:3 248:18 going 4:13,25 5:2,10,14 7:20 8:16 9:23 10:5 12:2,3 15:11 15:13,20 16:20 19:9,21,24 20:6 21:16,20 26:7,7 33:16 34:7 35:7 36:19,23 38:2 38:17,18 41:22 41:24 42:5 43:22 44:5,10 46:1148:2 52:22 60:14 61:9 62:21 65:25 66:3,20 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 14 71:12 76:21 84:13,15,16 86:15 91:24 93:22 94:19 98:12,15 99:15 99:16 100:17 104:23 106:9 107:7 108:24 112:6,19 115:13 118:3 118:21 120:7 120:12 121:12 123:6 125:3,19 126:8 128:2 129:3,13,19 131:12 132:5 132:13 134:8 134:20 136:8 137:1 139:11 140:8,23 142:3 146:16 149:16 150:15 154:8 157:18 160:9 161:3 162:20 166:18 168:3 168:24 170:6,9 170:9,11,21,23 171:1 174:8 179:16 182:4 182:11,13,15 183:12,25 184:15 185:14 185:23 194:2 194:12 195:10 196:2 201:2,9 201:11,19 204:20 206:21 207:4,9,18 208:1209:3 212:18 218:11 219:16 220:2,3 221:10,21 226:14 228:2,3 228:10,19 229:17 233:2,7 233:9,11,21 236:2,14 237:9 237:21239:9 239:11240:20 241:2,10 243:8 245:3,11,14 247:11,15,20 249:7 250:5 252:4,8 253:1 253:5 260:21 262:2,4,6,15 264:19,23 267:22 275:7,8 276:7,8,22,24 276:25 277:2 277:15,18,19 279:8,14,20,23 Goldstein 2:10 5:9,20,25 6:16 7:219:8 10:13 10:17,20,25 12:1,7,19 13:3 13:7,15,21 14:3,9,12,19 14:21 15:6,11 15:15 16:17 17:21 19:1,17 20:1,6 22:8,17 24:23 25:18 26:8,18 30:19 30:24 33:25 34:3 40:13 41:10,15,21 42:22 43:6,21 47:7 48:2,6,12 48:18,23 49:7 50:19 54:7,10 55:19 56:20 57:6 58:3,17 59:6,13,20 60:12 61:2,12 62:3,21 63:6 63:14 65:19,21 66:2,10,14,17 66:2167:20 68:12,17 69:3 69:14 70:24 71:2,6,10,14 71:18 72:15,19 73:11 76:21 77:12,24 79:11 80:21 81:10 82:25 83:18 85:3 87:21 88:10 89:10 91:6,17 93:3 94:14,25 95:3 95:11,25 96:12 97:15 98:12 99:15,22 101:14,23 102:14 105:16 106:10 109:5 109:15 111:10 111:17 112:8 112:14 113:13 113:19 115:24 116:20 117:20 118:11,20 119:3 120:2,9 120:20 122:10 122:18,22,25 123:18 124:3 124:19,23 125:8,22 126:12,25 127:14,25 129:3 130:4,13 131:15 132:20 134:11 135:21 136:7,25 137:9 138:12 139:10 139:22 140:18 141:12,21,25 142:7 143:20 145:8,16,20 146:9 148:2,8 149:9 152:11 153:19 154:7 154:18 155:4 157:22 158:19 160:12 161:5 162:12,19,25 164:13 165:7 165:19 166:16 167:4 168:12 169:4,21 170:10,22 171:6,9 172:12 172:13,15 173:6,11 174:18 175:4 177:10 179:16 179:21 185:23 187:17 192:6 192:10,25 195:18,23 198:8 199:8 202:2 203:15 204:19 205:19 206:5 207:14 208:4,11209:1 212:18 213:14 213:16,19 218:23 219:7,9 220:10 222:4 223:5,13 224:23 225:20 228:5,16 229:13 230:8 230:11,17 231:4,7,9,14 231:15 232:16 234:11,15 236:6 237:1,13 238:10,14,18 238:19,23 239:3,12,16 240:11241:9 241:18,25 242:2 243:7 244:3 245:2,10 245:13,18,21 246:15,23 247:4,9 248:5 249:2 250:9,21 251:9 253:4 255:2,4,9 256:2,9,13,15 256:20 257:18 258:4,19 259:5 260:13,22 263:17,21 267:20 269:16 269:22 270:2,4 271:9,18,23 272:4 273:9 274:6,9 275:5 275:17,25 276:3,14,18 278:2,9,17 279:12,19 280:1,8 284:3 284:9,21 Goldstein's 214:2 256:6 good 7:4 11:24 39:19 46:16 55:12 60:2 76:2 84:14 108:13 158:17 219:4 225:22 242:8 256:21 gotcha 40:1 42:11 159:7 170:5 189:1 gotten 48:17 117:18,22 government 45:6 159:25 166:21253:20 258:8,10 266:5 267:1,5 governments 34:15 56:4 254:1 grade 224:15 225:11 graduate 157:10 graduated 7:2 156:9,18 157:15 grain 259:12 260:8 granting 14:4 grasp 47:4 grent36:23 46:16 110:24 132:7 182:9 264:18 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 15 greatly 232:1 268:20 green 59:22 Greenwel11:23 176:23 281:8 281:16 282:7 282:19 284:18 Greer 161:25 244:12 Grey 3 7:4 46:8 266:3,7 270:14 Grievance 58:19 Grossman 158:14 ground 221:23 group 34:11 35:9,15,15 122:1,3 134:9 207:24 226:9 227:2 244:1 248:10,17 249:18 growth 252:5 guess 17:9 38:15 54:7,1155:13 91:1 103:19 115:19 117:7 136:7,9 141:9 155:20 203:17 212:13 230:2 269:18 guessing 54:6,9 54:12 136:6 guilty 65:24 73:10,15 Gulf 2:18 4:11 15:18 18:8 20:24 21:10 24:5,13,21,25 26:6,15,17 28:24 30:2,4,6 30:8 56:1,3 57:9 61:3,6,8 62:19 63:20 70:9,13 74:2 78:11 84:24 111:6 119:10 121:21 127:11 133:3,22 138:18 141:1,2 148:21 154:13 158:1 159:19 160:6 165:24 167:25 173:9 177:18 179:6 186:7,12 188:10 191:14 192:20 193:20 197:18 206:24 209:11,11 214:13,24 216:16,20 217:1,6,7 223:1,9,17 226:17,18 228:1,9 229:9 229:16,17 244:17 248:3 249:22 250:8 260:25 261:2,4 261:24,25 262:2,5,9,11 262:14,16,19 263:13 264:10 264:10,13 265:5,20,25 266:13 268:19 270:19 guy29:5 105:13 225:18 guys 184:23 218:20 219:3 hac 84:1 half 140:7,17 278:9,11 Hall 211:22 222:17,18 hallway 236:23 Hamilton 7:5 hand 98:4 handed 67:6 268:21 handle 46:3 59:22,23 159:23 231:20 handling 74:10 119:9 235:18 hands 141:4,5 handwriting 75:3 181:22 Hannah 163:2 163:12,15,25 243:11,14,15 272:7,15,18 happen 105:20 266:2 happened 85:18 144:10 148:7 164:16 195:14 198:25 202:18 261:1,22 happening 49:16 79:2 266:25 happens 59:18 124:12 150:24 194:23 252:18 happy 10:10 14:3 15:7 25:2126:9 31:13 32:25 49:22 66:5 67:11218:22 238:18,20 harass 227:7 harassed 235:22 236:12 harassing 208:23 harassment 235:15 236:19 237:7 Harbor 111:6 188:10 258:6 hard 13:10 165:5 174:13 184:21214:3 260:12 266:23 267:1 hate 124:11,13 He'll 245:20 head 155:15 259:16 heading 245:24 hear 52:7 104:12 124:8 155:17 173:16 215:8 248:15,17 heard 8:14 21:24 23:4 65:6 72:22 84:8 87:11 102:12 114:18 140:25 144:16,17 160:19 170:16 170:19,19,20 204:13 210:19 211:24 215:11 232:25 244:23 251:17 264:23 266:24 271:14 hearing 76:18 124:10 160:19 hearings 217:24 221:4 heavily 95:9,12 held 174:11 223:23 help 42:20 44:9 44:10 74:14,18 100:22 184:15 184:16 206:8 242:2 helpful 6:9 hesitating 259:1 hiatus 72:9 Hidden 111:6 188:10 high 6:21,22 7:1 7:2 158:25 199:12 223:24 224:6 higher 114:23 153:15 158:15 highly 10 1: 11 157:17 Highway 1:19 176:19 Hillsboro 198:15 hire 270:13 hired 21:1,14,19 28:24 35:2 44:23 133:14 165:24 265:10 history 186:18 187:6 243:22 hit 154:3 Hm-hum 4:17 51:5 255:24 Hochman 2:19 2:20 20:18 42:8,11,16 52:2,6,14,17 52:24 59:20 71:24 80:2,9 80:13 93:14 99:5,11,14,22 100:3,13 113:20 114:3,9 126:18 129:10 129:24 132:9 136:8 157:21 171:18,24 172:2,6,9,18 172:22 173:2,5 173:8,15,18,22 174:1,4,15,23 175:3 177:19 177:20 180:7 180:10,14,18 180:21 181:3,6 181:12,17,20 181:23,25 182:6,10,17,22 183:2,6,15,24 184:12,19,24 201:8,19 218:8 219:16,23 231:17 232:11 232:15,19 233:11234:3 241:10 263:18 267:21277:1,4 277:7,13,18,23 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 16 278:12,15,18 278:21279:1,5 279:13,20 280:4 284:22 Hochman's 262:18 hold 7:2134:25 90:16 132:20 206:23 229:7 holds 90:14 holiday 232:23 home 84:24 188:9,15 224:18 homes 188:15 honorable 30:9 hope25:21 82:24 149:7 179:10 261:22 horse 241:24 242:4 hostility 271:14 273:4 hour 113:5 114:12 132:11 158:1,2 159:4 159:8,11,23 167:19 218:23 278:6,9,11 hour-and--a-h... 42:1 hour -and -a -half 219:15 hour-ish 132:12 hours 218:11 219:20,24 277:5,14,25 278:10,19,23 house 9:15,17 106:9 214:13 214:25 215:3,7 225:2,10,11 houses 144:15 145:13,14,25 146:1,2,3 huge 240:8 hundred 35:13 53:22 56:4 143:8,9,12,13 187:10,16,21 190:21203:18 203:22 204:6,9 204:11205:22 206:3,12,23 207:2,13,23 265:9 266:4,5 hundreds 244:1 hungry 39:13 131:25 Huntington 102:13 103:14 hurricane 189:4 hurt237:16,17 husband 11:8 husband/wife 224:4 hypothetical 89:20 160:25 hypotheticals 47:19 I I -N -D -E -X 3:1 178:1 idea 21:24 22:2 22:5,13 48:17 57:19 104:15 146:17,18,19 148:6,9,20 187:12,13,14 187:24 219:4 237:20 250:12 265:4 Identification 174:22 260:16 identify 30:20 II175:8 176:14 185:10 illegal 56:5,19 imagine 209:20 immediately 50:11239:20 265:9 immoral56:4,18 immunity 168:17 169:3 169:10,11,12 169:14,15,16 169:18,20 170:2 impact 184:14 implicated 209:16 important 105:22 106:8 108:6 109:3 impossible 209:14 250:16 impression 128:1 impressions 97:4 97:24 128:4 improper 115:20 179:17 227:7 improperly 262:11 inactive 74:3 110:11 inappropriate 207:25 249:14 incensed 265:12 Incidentally 31:20 incidents 144:23 include 45:9 61:10 68:21 202:6 included 78:7 95:18 including 12:16 36:18 217:24 221:3 252:6 income 23:3,4,7 23:8,12,13,14 96:6 97:11 160:4 incorrect 14:20 115:12 increasing 252:6 incurred 36:14 274:17 independent 49:13 indicated 31:23 49:14,16,19 78:8 91:8 243:15 indicating 172:23 indication 31:15 193:12 indigent 243:23 individuals 272:8 indulge 212:25 indulged 10:5 industry 158:5,7 infallibility 6:2 infallible 5:24 6:6 inform 55:25 information 8:2 9:24 12:9 19:22 24:3 56:7 59:19 61:22 70:20,21 73:9 77:10 81:23 86:11,14 86:17 138:9 146:23 147:12 147:14 149:20 201:4 204:15 209:19 240:19 268:5 informed 158:22 249:5 initially 166:24 initials 16:25 135:12 input 88:3 inquire 8:1 10:21 inquiries 91:12 inquiring 12:8 14:25 inquiry 12:17 91:197:2 100:11 103:24 111:25 129:14 insignificant 42:19 insisted 36:2 instance 150:1 150:10 153:21 157:12 158:1 196:10 251:17 instruct 10:15 10:17 19:25 20:7 66:7 instructed 35:24 49:11 instructing 10:11,13,23,25 66:10 122:23 123:1 instruction 183:7,7 instructions 128:9 insult 184:17 insurance 158:4 158:5,7,24 255:12,17 257:1262:22 intend 232:5 271:4 intended 208:23 208:23 243:16 intending 25:23 258:1,2,3,5,12 258:16 intent 45:2 183:21264:9 265:24 interactions 124:21,24 interchangeably 108:25 228:14 interest 269:1 interested 67:15 282:14 internet 25:6 164:22 165:5 165:11,18 Interpol32:14 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 17 interpreted 117:4 interrupt33:24 71:3 132:3 interrupted 125:12 interrupting 68:17,18 71:5 132:4 interstate 74:12 85:12,25 interview 33:3,9 60:1240:8 259:18 interviewed 18:4 29:10 33:1 interviews 29:21 247:21 intimidate 142:11,20,25 144:24 207:21 intimidated 235:22 236:11 intimidation 235:15 236:19 237:8 introductory 186:11 inundating 251:22 invented 170:25 171:3 investigate 93:13,18 138:7 investigated 138:17 240:16 275:23 investigating 76:8 90:4 investigation 29:23 88:4 94:4 103:11 191:25 259:15 investigative 4:19 128:23 invitation 18:6 invite 120:18 224:17,18 276:22 invited 119:2 inviting 267:24 invoice 263:6 involve 45:21 involved 13:20 32:8,9,14,19 35:17 45:22 95:10,12 153:23 158:12 160:21 198:12 237:20 239:8 260:1264:16 267:3 273:22 274:1,2 involvement 215:2 264:9 265:2 involving 36:7 239:19 irrelevant 12:12 irresponsible 248:10,13 Isen 136:11,12 136:24 137:3 137:15 152:14 isolate 205:13 issue 63:21 68:23 76:7 79:15 134:5 140:23 142:17 181:14 233:12 252:7 258:24 issued 215:14 216:3 257:12 issues 7:24 189:5 189:9,10 202:1 207:10,10 231:25 232:1 272:18 issuing 214:18 216:2 items 127:9 jackass 155:6 Jay 200:23,25 Jeffrey 2:19 177:19 284:22 Jersey 98:9 101:4,22 136:19 191:7 191:13,23 192:3,5,12,14 192:21,24 193:22 194:24 195:1,4,9,9,15 195:21 196:1 196:12 202:22 203:2,7 Jiffy 189:5,14 Joann 37:20 57:21,23 65:13 74:19 75:7 95:19 159:15 job 75:20 159:2 232:4 237:18 237:19 Joel 29:5 42:21 43:18 47:3 48:15 51:3,9 51:16,16,17 55:15 61:24 65:11 124:22 124:25 160:18 245:1246:10 249:9,24 John 105:9 181:11 189:5 Johns 189:14 JOHNSON 2:20 177:20 Johnstown 104:12 111:15 joint 28:16 joking 235:9 Jonathan 36:18 37:151:3 68:22 69:11,18 69:22 70:5,13 70:17 72:17 73:5,10,15,20 73:24 74:1 75:17,18 78:8 78:19,22 79:6 79:13 83:11 84:23 85:13 86:2 88:8,24 89:7 91:2 93:13,19 94:3 94:6,8,10 96:4 96:8 98:7 101:3,5,12,20 103:4,4,4,24 104:3,4,4,8,17 108:22,23 109:23 110:7,7 111:4 119:1,6 119:8,13,17 127:7 224:24 225:7,8 Jones 244:14 262:24 Josh 213:24 Joshua 2:10 177:10 284:3 284:21 judge 20:20 58:20 59:25 68:22 69:11,18 72:12,14 76:4 76:10,13 105:8 118:8 138:19 138:21 139:4,5 144:3,4 157:11 200:15 202:12 202:13,16,18 202:20 205:6 Judge's 7:22 judges 138:6 judgment 63:17 judicial 151:21 193:21,25 200:16 202:10 213:6 222:19 July 42:18 62:16 211:12 237:22 238:12 June 211:12,15 226:14,15 245:23,25 281:13 282:16 284:1 Junior 11:11 jurisdiction 186:8 jury 59:25 Justice 208:18 justiciable 258:24 K keep 71:4 86:12 107:7 201:9,11 214:4 233:7 243:1266:22 keeping 7:23 38:24 257:20 277:10 kept39:14 252:14 265:17 Kevin 87:9,20 kicks 268:6,8 kid 18:18 kids 155:18 kill 33:20,21 34:15 44:20 45:14,18,24 46:15,24 253:24 264:7 269:4 270:14 killer 44:23 55:9 kind 13:25 47:23 81:12 90:5,8 92:18 189:6 248:12 249:15 260:12 kindly 29:2 66:13,15 82:3 123:3 209:23 238:22,25 KISSANE 2:11 177:11 KISSANE,P.A 284:4 knees 253:22 265:25 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M knew 49:4,5 106:5,9 111:22 160:14 204:10 204:12,13 221:21223:16 259:22 know 6:20,25 7:3,16,17,18 8:3 10:4 11:15 12:22 19:4,6 19:20 22:24 25:10 27:22 28:3 29:5,6,8 29:12,13,14,14 29:17,18,19,20 32:3,6,12,13 32:15 37:18 45:8 48:22 50:9,13 51:25 52:14 53:17 54:21,2157:5 57:15,17 58:5 58:6,7 60:5 63:19 70:21 72:10 74:18 75:7 76:13 87:9 89:1,8,22 90:5,8,19,22 91:196:24 98:21,23 101:5 101:11 102:6 103:17 104:21 106:13 107:4 111:8,16 112:25 118:3,7 119:4,8 125:6 125:15 127:21 129:17 130:8 132:13 135:17 136:11,14,15 136:15 137:15 140:2,5,6 141:3 142:14 143:3 144:7 146:4,5,6,7,10 146:18 148:5 148:13,16 152:7 153:2 154:19 156:12 156:14,15 157:16,21 162:17165:8 166:4 167:1 168:6,11 169:7 171:24,25 172:2,3,4,6 174:1 179:14 182:18 184:3,4 185:3,18,22 187:15,22,25 188:12,14,24 189:7,17,25 190:2,4,10,16 190:19 191:13 191:13,16,22 191:24 193:19 193:25 196:4 196:23 197:1,2 197:21,22 198:1 199:17 201:14 202:9 203:1,3,3,4,8,9 205:17,20 206:13 207:20 209:13,16,16 209:18 211:4 212:2,4 214:20 215:4,6,13,18 215:23 217:6,8 218:19,20 220:22,24 223:11,16,23 225:13 226:11 227:16,17,19 230:14,21 231:18,18 234:2,24 235:1 235:3,4 237:6 237:8 238:19 239:10 242:23 243:10 244:22 244:24 245:19 248:2,11,12 249:21250:11 250:22 252:7 259:3,18 262:24 268:17 268:17,19,20 269:6 273:22 274:2 275:13 277:7,25 278:24 279:8 knowing 146:13 230:23 knowledge 12:23 20:4 32:7,12 32:24 37:16 44:24 53:7 101:12,20 104:20,22 110:25 111:12 137:21,23,24 143:18,24 149:10,12 163:25 164:6 171:22 186:15 188:14,20 194:22 195:25 205:9 212:1 215:12 216:19 217:10 218:3,4 220:20 221:1 221:24,25 222:12,22 223:20 224:1 227:14 243:25 249:10 250:15 274:12,25 275:2 knows 136:13 183:13 L L2:19 177:19 lack 72:13 75:10 245:8 258:23 lady 106:22 114:19,19 201:7 238:17 Lakes 2:12 177:12 284:4 land 187:10 large 8:11 156:11 159:1 281:22 late 221:11 latent 249:18 Lauderdale 2:22 6:22 177:22 laughing 185:2 Laura 200:14,15 law 2:11,20 5:14 5:21,22 7:7,10 11:17,18 31:25 33:19 34:16 35:6,8,10 37:1 37:4 38:6,12 40:22 45:22,24 46:2,17,20 65:8,14,24 67:2,2,22 69:12,20,25 70:3,12 72:18 73:10,14,16,20 74:10,12 75:12 75:22 76:1,9 76:12,17,19,20 77:2,3,4,5,9,22 78:2,3,5,20,20 78:23,24 79:4 79:10,14,15,16 79:17 80:18,19 83:15 85:2,12 85:16,25 86:3 86:6 87:6,25 88:9 89:2,9,22 90:195:4 105:21,23,25 107:6,12,19,25 108:7,23,24 109:1,21,23 110:1,4,6 112:1,2,5,22 113:7 115:9 116:9 117:4 118:17 119:20 127:8 128:12 128:24 131:3 134:2,3 142:10 142:19 155:24 156:1,3,4,8,10 156:19 157:10 157:13,14,15 158:21 168:5 168:11 173:18 173:21 177:11 177:20 189:21 190:1 191:6 192:3,3,14,20 192:23 193:2 194:22,23 195:2,7,8,21 196:1,6,20,23 197:7,9 203:5 210:15,18 211:3 212:13 213:7 224:22 227:22 229:11 236:17 237:3 240:21244:13 244:14 252:7 252:17,18 253:21254:5,7 258:11262:24 264:20 266:7 266:14 267:6,8 269:20 270:8 270:16,20 272:15 274:23 276:8 284:4 laws 210:7 234:20 235:2 252:20 254:6 lawsuit 4:16 45:4 46:16 210:6,14 211:5 211:5,7,8,13 211:18,24 212:12 213:3 231:25 235:10 260:1 lawsuits 33:18 34:16 35:20 45:1146:20 119:10 210:17 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 m 211:2,14 227:6 227:8,14,17,18 227:20 234:18 234:21,25 235:16,18,24 243:1,5 246:3 253:24 264:8 265:21266:9 lawyer 11:4,5,8 32:16 35:7 40:20 48:22 55:22 56:12,14 57:1,3 70:12 73:22 78:23 81:7,24 85:13 85:18,20,22,24 86:6 87:9 88:2190:3,5,8 90:10,1197:6 109:22 117:19 117:23 119:14 120:18 122:8 123:7 126:24 128:7,8 150:15 150:24 153:6 154:16,16 156:2,15,16 158:3,13,16,16 158:17 159:7 159:10,14 170:3 180:15 180:20,20 203:7 207:16 209:16 229:19 240:10 267:7,7 270:7 272:23 272:23 277:8,9 lawyer's 157:7 lawyer/client 38:2 133:4 134:15 147:10 166:13 186:1 212:3 lawyering 91:5 167:17 lawyers 18:2 36:17 37:21 47:16 56:19 74:6 75:10 85:15 95:17,18 95:20 96:2 117:3 134:9 150:16 153:2 158:4,6,8,12 159:1202:6,8 209:4 242:25 251:8 253:18 lay 97:8,9,13,19 111:9 112:13 112:15,20,21 120:8,10,14,15 120:15 123:6,9 123:10,23,24 124:1 126:10 126:16 128:6,7 128:10,18,19 128:21 131:20 131:21 134:6 143:4,5 144:22 195:12 196:3,5 202:25 203:1,6 207:11209:20 250:17,19 251:25 252:16 253:7,25 254:2 254:8 laymen 133:7 180:9 208:14 209:15 laymen's 133:23 134:1,3 145:19 192:9 208:3,7 209:9 248:20 248:21249:4 250:7 lead 200:21,22 200:23 201:17 233:24 League 262:23 learn 26:3 38:19 learned 36:11 148:13,14 254:4 learning 55:1 226:20 leave 218:11 234:2 led 5:17 leeway 7:25 12:8 14:25 left 16:8 218:23 278:11 legal 5:11,15 16:10 17:11 25:16 28:14,18 28:21,22,23,25 31:4 34:18 43:23 44:7,8 47:20,25 48:1 48:8,10 51:4 55:20,23 56:22 60:25 64:25 96:16 97:2,2,3 97:18,19 112:9 112:16,18,19 116:10,17,23 116:23 120:3,7 120:11,16,17 121:8 122:1,3 123:17,19,20 123:25,25 125:3,4 126:7 126:8,8 128:3 128:3,8,21 131:14,14,18 131:18,21 133:6,20,21,22 134:7 141:20 142:1 143:5 156:21 157:2,4 158:22 161:2,3 162:10,14,21 163:12 164:17 164:20 165:3 165:20,22 168:18 170:18 170:19 185:3 185:25 192:7 195:11 196:2 197:4 207:4,10 207:25 208:3 209:3 210:9,9 210:12 212:20 212:22 214:22 226:10 228:2,3 228:10,11,12 228:17,19 229:6,15,16,17 229:20 236:20 236:24 237:4 240:14 241:2 244:5,8,20 245:12 249:4,5 250:6 252:3,3 252:4,6 253:2 265:16,16 266:22 267:2 272:5,25 legally 55:18 234:6 legislative 222:19 Legislature 196:9 197:10 legitimate 46:22 227:12,19 lesson 8:8 let's 6:217:1 20:9 31:17 37:9 61:21,21 63:25 68:25 69:2 70:2,2 80:3 106:15 113:12,14,16 121:15,15,16 152:4 182:20 182:25 183:22 184:5 191:4 194:20,21 225:19 234:3 235:9 254:11 254:16 letter 37:21 59:8 59:10 88:14,16 94:1,4,5,9,15 96:4,8,20 102:22,25 103:2 111:25 115:8 125:17 125:18 127:2,4 127:6,17 129:6 129:7,12,15,19 245:24,25 246:6,10 247:2 258:6 259:19 259:21,23,24 260:6 284:10 letter's 96:22 letters 115:10 letting 129:17 liability 246:12 liable 244:2 license 107:21 173:19,21 licensed 135:18 195:9 196:11 life 9:23 10:1,21 172:16 light 250:4,5 258:23 259:17 259:17,22 liked 223:10 264:21 likewise 214:10 226:6 limit 152:4 line 3:17 93:15 99:17 178:20 212:19 283:4 Lisa 1:23 176:23 281:8,16 282:7 282:19 284:18 listed 30:6 listen 64:7 66:6 listened 270:17 listening 122:5 litigate 184:20 litigation 4:22 5:8 13:16,17 23:2135:23,25 38:7 50:2 66:19 137:17 142:14 147:7 160:21 167:15 167:16 168:16 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 20 200:1229:8,9 234:6 236:9 239:8,10 251:4 251:6,6 255:21 255:22 267:14 273:23 litigations 61:1 119:21 little 6:18 63:25 90:12 130:9 184:9 223:10 241:24 242:4 live 9:11 10:6 187:12 188:12 246:6 lived 9:13,18,21 78:11 living 70:5 74:2 85:10 110:1 189:7,17 LLC 87:2 144:15 145:13 145:14 LLM 7:12 loan 274:18 lobby 221:12 local 34:14 266:6 located 78:13 187:9 188:9 long 9:13,17 11:18 13:24 20:24 33:15 34:22 40:1 50:25 51:1 53:10 62:8 65:12 98:8 101:4,21 127:22 136:19 136:21 142:24 160:9 189:18 190:9 191:22 191:25 192:1 192:21 193:15 193:21201:1 213:3 214:8 242:2 256:2,17 267:3 longer 14:10,12 47:1149:4 160:2,7 164:18 look 11:20,23 22:3 25:21,21 28:131:18 45:17 50:5,6 50:16,20 53:14 54:5 58:25 61:17,18 79:6 79:22 86:25 89:18 93:10 100:20 101:16 128:11 129:15 135:2 137:3,4 137:6,14,16 147:1,7,15,20 148:10 156:9 159:9 160:4 168:19 175:4 193:6,7 199:19 220:14 264:13 268:15,23 looked 26:25 49:3 50:7,10 50:17,25 75:8 84:3 138:10 157:7 159:20 188:17 227:20 266:25 looking 39:14 55:4 79:21 102:23 103:18 110:17 111:3 137:7 157:22 166:22 193:9 209:15 229:11 244:14 251:5 looks 146:18 148:21211:10 260:24 261:19 261:21 lose 72:9 losing 167:22 loss 268:11 lost 159:21 160:5 lot 37:6 104:11 153:16 156:12 168:1 191:24 191:25 221:12 242:5 lottery 112:6 love 39:22,22 76:24 180:12 232:3 268:17 268:18 low 158:4,25 lunch 38:24 39:12 42:23 43:5 63:10,11 100:10 108:16 112:23 113:10 131:24 132:8 132:21278:6 lying 60:3 machine 251:19 252:11,12 machinery 251:20 mad 35:16 madam 12:18 29:2 81:11 82:2,15,23 92:2 99:21 113:20 114:13 121:2 123:4 175:5 209:22 278:2 279:18 magic 77:11 Magistrate 20:9 20:20 212:20 mail 81:8 105:22 107:5,5 109:3 109:3 110:1 main 73:22,23 85:21254:25 maintained 108:8 116:13 majority 16:11 making 33:16 45:146:23 52:24 76:13 83:16 91:12 96:19 104:13 139:5 142:20 156:11202:23 208:25 249:19 264:10 265:5 269:9 271:6 man 30:10 33:16 37:3 184:24 185:1225:8 267:10 268:24 269:12 manager 149:18 217:3,9 235:12 manner 34:19 277:20 March 165:25 205:14,14 222:11,14,23 mark 174:20 199:12 marked 174:21 174:23 179:7 181:7,18 233:14 260:16 267:23 marking 280:7 married 106:5 Martin 1:4 2:2 4:8,10 125:21 125:24 126:3 137:4,7,14 161:11,14 162:8 176:4 177:2 179:5 186:4,5 197:16 284:7,22 Marty 59:21 161:12 materials 40:23 78:7 127:11,23 127:24 math 278:8 mathematical 23:9,10 matter 4:9,12 6:5 7:15 14:5 14:24 15:3 17:2,2 25:20 60:20 116:8 120:10 151:1,6 151:8,9 179:5 194:7 200:9 228:24,24,25 229:6,7 232:23 240:22 245:5 261:6,20 263:12 271:13 277:8 matters 4:18,23 4:24 25:14 37:2 48:1 60:19,25,25 90:15 103:11 119:15 128:21 131:6,21 147:11 167:25 maximum 222:17 mayor 1:8 176:8 211:23 212:5 214:14 215:1 234:22 235:11 243:4 mayors 137:18 226:4 mean 4:24 5:7 11:15,21 12:5 13:3,17 16:3 18:16 29:13 37:6 43:23 54:6,8 57:24 58:2 59:5 75:13 82:17 86:9 95:13 107:24 115:17 122:2 128:10 137:24 144:4 147:19,19 148:11 151:18 153:6 155:6 156:14 157:10 157:13 158:14 165:8 170:13 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 21 187:18,22 191:12 200:1 203:14 212:10 216:9 223:16 244:22 250:24 258:9 259:12 273:8 meaning 8:15 153:16 means 29:14 97:17 152:7 168:8 204:6 205:18,20 meant 165:16 203:17,19,22 203:23 205:21 205:24 206:12 mechanism 46:24 media 172:17 mediation 116:6 116:8,13,14 117:16 130:10 130:21,22 131:13 163:19 165:16 243:9 meeting 31:20 117:7,8,10,14 118:18,22 119:25 120:19 121:11 123:11 123:16 130:20 131:9 149:4 163:16,19 164:1,2,16 221:11226:23 226:25 235:7 258:8 meetings 35:3 148:25 149:5 221:12 226:7 243:14,15 member 26:6 32:2 69:23 70:14 89:17 103:16,21 119:18 223:1,4 223:8 240:24 240:25 members 12:11 149:15,18 memory 39:19 135:19 mental97:3,24 127:25 128:4 mention 76:4 mentioned 28:10 33:20 72:12 159:18 197:16 197:17 254:19 merely 33:15 merit 1:23 176:23 234:23 281:16 282:19 meritorious 234:19 merits 235:14,19 235:20 message 92:17 215:6 217:18 246:17 messages 19:12 214:14,25 215:3 217:22 220:19,25 met 29:10 87:10 136:16 148:20 206:15 246:22 Michelle 114:19 114:22 middle 251:15 mildly 184:10 million 22:4,6,15 53:18 136:23 147:25,25 mind 6:10 38:24 42:4 106:11 131:25 146:13 193:15 197:9 203:17,21 204:7 205:13 206:10 209:15 216:10 mine 87:7 255:19 259:4 minute 28:10 113:14 114:10 114:11 248:17 253:20 minutes 40:2 55:2 131:25 170:7 mischaracteri... 77:25 91:18 125:8 153:20 238:14 misplaced 106:1 missing 190:12 mistake 269:18 269:18 mistaken 27:9 116:7 136:19 157:23 169:15 169:24 214:9 224:13 misunderstan... 196:18 Mitchell 105:9 model 46:7 270:22 moment 114:4 172:11 179:4 180:25 278:24 279:1 moments 123:12 Monday 264:19 money 26:7 36:5 36:13 39:10 160:6 167:22 168:1215:15 255:16 257:25 267:4 269:3 274:23 monies 270:21 273:24 month 135:24 167:24 205:14 226:13 months 11:22,22 27:19 28:3 221:10 moon 72:13,22 moral 55:23 morally 55:17 Morgan 1:8 21:6 133:3 176:8 213:5 234:22 235:3 243:4 245:25 246:1 258:9 261:4 262:21284:7 Morgan's 244:25 245:23 mothers 223:17 224:14 motion 14:4 65:8,12 66:14 66:18 67:3,5,6 67:10,17 73:13 73:19 74:1,9,9 74:13 76:1,16 76:24 77:1,14 78:1,7,16,19 78:21,22 79:3 79:4,12,13 82:11,12,13,14 82:16 83:10,21 83:21,24,25 84:2,12,16,18 85:6,8 86:1 87:22 88:5 93:25 104:7 105:4,4,5,6,7 109:16 110:15 110:17,18 111:4,25 112:4 112:11 141:13 141:18 142:2,5 142:9,12,22 151:25 236:16 237:2 274:5 motioned 84:11 motions 63:1 motivation 197:22 mountain 138:11,13 139:2 168:9 171:4 250:20 250:23 mouth 195:17 move 6:15,16 9:9 13:24 48:12 54:10 63:25 65:19 69:20 78:14 94:14 124:8,12 124:13 136:8 171:6,10 206:22 227:4 230:11231:10 231:15 239:3 242:13,20 245:21271:19 274:9 276:3,14 276:18 moving 5 3: 10 168:13 multiple 82:19 119:20 139:20 139:24 153:13 153:14 multiples 274:17 multiplier 274:19 municipal 186:13 189:24 municipalities 190:11 191:11 193:18 203:13 205:17,25 206:16 216:18 216:23 264:11 municipality 187:8,11 MURDOCH 2:20 177:20 mushrooms 39:23 N name 4:8 8:10 8:13,17,24 9:1 11:10 17:18 31:25 35:14 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 22 51:6 86:19,23 114:20 141:15 144:18 146:6 146:17 148:12 148:17,19 149:2 162:23 188:18 191:21 197:19 261:11 named 27:25 28:2 29:5 37:3 87:9 95:7 136:11213:20 243:21247:10 names 63:4 137:18 National204:18 nature 21:16 121:24 134:21 135:5 136:21 149:25 near 226:13 necessarily 13:12 116:16 necessary 59:1 234:19 235:1 need31:19 41:24 49:21 64:22 69:8 71:2 75:3 92:17 96:23 113:13 124:8 127:1 169:15 175:1213:22 233:9 238:20 238:23 242:6 253:16,16 255:7 268:25 270:15 needed 114:10 270:8 needs218:12 negotiated 158:9 neighboring 216:18,23 Neither 232:16 net 23:7,8,11,12 23:13,14 never 8:14 21:11 22:2 25:6 26:24,25 32:7 32:1135:3 39:10 53:8 54:2,13 79:5 143:9 159:19 160:14,14 161:19 172:15 188:17 190:1 197:6 203:1,2 210:11211:24 215:2 217:20 217:21226:21 227:20 242:17 242:20 256:7 264:17 274:24 new 7:5 85:16,17 98:8 101:4,21 113:3 136:19 143:11 156:11 183:20 191:7 191:13,23 192:2,4,12,14 192:21,24 193:22 194:24 195:1,4,8,9,15 195:21 196:1 196:11 202:22 203:1,7 232:1 Newport 2:3 177:3 newspaper 133:18 140:25 204:23,25 205:7 newspapers 205:4,6 nice 237:15 night 150:2,4,5 150:14 221:13 232:9,11 nine 54:16 189:20 190:13 Nineteen 234:11 234:12 non -client 21:12 non -facts 66:1 non -lawyer 100:5 non -legal 161:4 161:7 non -stopped 252:14 nonsense 268:12 nonsensical 268:10 normally 39:21 167:20 north 1:19,24 176:19,24 188:10 198:15 199:6 281:18 282:21284:19 Northwest 108:1 not-for-profit 33:14 34:8 36:9,12 46:21 267:13 270:13 275:9 Notary 281:8,22 notebook 54:18 54:19 noted 103:11 246:1 notes 52:8 72:2 179:25 180:3 282:10 notification 81:25 notifications 81:8 notify 119:24 notion 219:23 232:19 Nova 6:22 number 21:24 27:20 49:8 52:20 54:13 58:24 77:23 78:12 83:25 84:10 93:17 103:13 106:15 106:16,17 119:22 138:7 156:10 169:9 187:15,19 190:13 206:10 212:17,23 216:6,7,8,9,14 228:18,22 229:1233:15 241:17 245:17 246:3 254:17 260:14,15 268:1280:7 numbered 102:23 103:9 103:10 125:18 numbers 191:2 254:19 numerous 29:25 30:1,3 34:14 49:17 119:14 189:23 190:16 190:17,19,21 190:23,24,24 191:1,2,10 192:18 193:16 193:19 197:14 203:12,14,16 203:22 204:5,8 204:8,11 205:16 206:10 206:12,14,15 207:7 210:16 216:24 226:2,3 226:6 O'Boyle 1:4 2:2 3:5 4:7,8,10 5:16,23 6:3,8 6:17 7:21 8:6,9 9:9,10,24 10:11,15,19,23 11:2,3 12:4,7 12:18 13:5,12 13:18,24,25 14:7,10,16,20 15:4,9,13,16 15:17 16:22 18:13 19:7,11 19:19,24 20:3 20:9,12,15,19 20:22 22:9,20 25:9 26:1,12 26:2128:6,9 29:2,4 30:12 31:2 34:2 35:6 36:18 37:8 40:15 41:11,13 41:16,22 42:2 42:9,14,17 43:144:2,15 44:17 47:10 48:3,9,14,21 49:2 50:3,21 52:3,5,9,23 53:2,6,11 54:14 56:8 57:10 58:8 59:2,7,15,21 60:15 61:5,15 62:6,24 63:6,9 63:24 65:8,14 65:22 66:2,7 66:13,15,20,24 67:2,13,23 68:16,18,23,24 69:2,5,8,9,11 69:25 70:3,5 70:12,18,25 71:4,8,12,16 71:25 72:3,7 72:16,17,24 73:5 74:10,16 75:18 76:17,19 77:8,17 79:6,8 79:13,20 80:3 80:5,7,11,15 80:16,17,18 81:1,11,16 82:2,10,23 83:7,11,22 85:7 86:3,16 87:25 88:6,8 88:12,24 89:8 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 23 89:15 91:14,20 92:2,9,15 93:5 93:13,19,20 94:3,6,8,10,17 95:1,5,15 96:3 96:4,8,18 98:1 98:19 99:1,11 99:13,21 100:9 100:25 101:1,3 101:5,12,17,21 102:1,17 103:4 103:4,4,24 105:18 106:14 106:22 108:11 108:17,20,22 109:8,17,23 110:4,7,7,16 111:14,21 112:1,12,17 113:4,8,11 114:1,4,7,11 114:16,17 116:2 117:1,24 118:14,23 119:1,6,7,8,13 119:17,19 120:5,13,22 121:2,9 122:12 122:16,20,23 122:25 123:3,5 123:22 124:6 124:20 125:1 125:11,21,24 126:1,3,14,21 126:22 127:5,7 127:7,18 128:5 128:24 129:23 130:1,7,17 131:16 132:1,4 132:12,18,23 133:1 134:16 136:1,10 137:4 137:5,7,12,14 138:15 139:14 140:1,24 141:17,22 142:4,10 143:1 143:16,22 144:14 145:11 145:18,22 146:11 148:3 148:15 149:11 152:13 154:4 154:10,21 155:9 159:6 160:22 161:8 161:11,12,15 162:8,15,22 163:14 164:15 165:9,21 166:20 167:9 168:15 169:6 170:1,15 171:2 171:7,12,15,18 171:25 172:4,8 172:11,14,17 172:21,25 173:3,7,12,13 173:17,19,20 173:24 174:3,5 174:7,13,16,20 175:1,5 176:4 177:2 178:6 179:2,5,9,20 180:1,5,8,10 180:13,16,19 180:24 181:9 181:16,19,25 182:4,8,14,20 182:25 183:5 183:11,17 184:3,8,11,17 185:5 186:2,4 186:5 188:1 192:8,16 193:23 194:5 195:19 196:15 197:16 198:9 199:14 201:6 201:11,16,18 201:24 202:5 204:1,22 205:1 205:2,8 206:2 206:7 207:15 208:6,12 209:5 209:22,24 213:1,9,17,21 214:4,5 217:13 218:19 219:2,4 219:12,13,20 220:2,6,13 222:5 223:6,14 225:4,9 227:3 228:6,21230:1 230:7,12,19,25 231:8,12,17 232:3,13,25 233:18,21 234:1,13 236:17,22 237:3,5,25 238:6,11,17,22 238:25 239:13 240:1,17 241:16,20 242:7 243:20 244:6 245:6,16 245:20 246:9 246:18 247:1,7 247:17 248:19 249:8 250:18 251:3 252:1 253:9 254:12 254:15,18 255:3,6,10 256:14,19 257:23 258:9 258:14,20 259:6 260:17 260:24 261:2,3 261:8 263:3,5 263:12,19 264:1266:7,14 266:23 267:16 267:24 268:2 268:13 269:10 269:17,23 270:5,8,24 271:1,10,17,20 272:1273:2,12 274:7,10 275:10,18 276:1,5,16,19 276:21277:12 277:15 278:24 279:2,5,18 284:7,22 o'clock 183:4 218:9 219:25 221:11232:9 232:11,17 279:10 O'Connor 37:20 57:20,23 65:13 95:19 123:12 159:15 170:8 170:12,13,25 212:15,15 213:4 236:2,13 243:4 260:24 261:3 263:12 O'Connor's 57:21 O'Donnie 148:16 O'Hare 17:1 19:1127:2,4 27:17,24 28:2 62:19 80:1 118:24,25 119:5,20,22 131:8 151:23 151:25 160:9 197:25 242:25 243:12,14,17 245:7 246:11 246:16,19,20 247:10,13,18 259:19,20,25 260:7,11 263:20 264:4 264:16,18 265:14,15 270:18 O'Hare's 119:9 119:14,25 265:2 oath 4:3 266:10 281:1 object 5:9,20 12:1 16:17 17:21 19:1,17 22:8,17 30:19 43:2147:7 48:2,18,24 49:7 50:19 55:19 57:6 58:17 59:6,13 60:12 61:2,12 62:3,2163:14 66:3 67:20 69:14 72:15 73:1176:21 77:24 79:11 80:2181:10 82:25 83:19 85:3 87:21 88:10 89:10 91:6,17 94:25 95:11,25 96:12 97:15 98:12 105:16 106:10 109:5,15 111:10,17 112:8,14 115:24 116:20 117:20 119:3 120:2,9,20 122:10 123:18 124:23 125:22 126:12,25 127:14,25 129:3,17 130:4 131:8,15,17 134:11 139:10 139:22 141:25 146:9 149:9 152:11 153:19 154:7,18 160:12 164:13 165:7 169:4 170:10,22 179:16 185:23 187:17 192:6 195:18,23 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 24 198:8 199:8 202:2 204:19 205:19 206:5 209:1212:18 213:14 223:5 223:13 224:23 228:5,16 229:13 231:15 236:6 237:1,13 240:11243:7 244:3 245:2,10 245:21246:15 246:23 247:4 248:5 249:2 250:9,21251:9 253:4 257:18 258:4 260:13 263:17,21 270:2 272:4 275:5 276:14 objected 36:15 objection 40:13 99:17,23 100:23 101:14 129:4 185:24 238:14 276:3 objections 12:22 objective 129:1 obligated 122:8 123:7 obligation 45:5 88:21 119:24 127:12 229:12 240:25 obligations 89:13,14 234:5 246:12 obscure 21:19 observation 143:4,5,5 observer277:11 obtain 16:9 267:4 obtained 93:24 104:24,25 obviously 224:25 occasion 146:21 occasionally 16:9 210:3,23 occupies 87:6,7 occupy 87:7 188:24 occupying 188:9 188:19,20 occur 131:3 occurred 163:15 164:1 occurrence 246:3 Ocean 223:8 odd 182:11 offended 250:1,3 250:3 offensive 249:17 249:23 offer 161:7 offhand 153:9 office 1:18 15:9 15:12,22,23,24 16:1,5,8,19 17:14 22:22 35:9 70:11 73:21,22,23 74:7 79:1,1 83:12 85:16,17 85:21,22,24 86:12 105:1,2 116:7 153:3 159:3 176:18 240:3,18 261:1 262:1270:9 275:20 offices 2:11,20 35:8 86:13 177:11,20 284:4 official 222:8 258:8,10 officially 278:5 officials 217:1,7 222:15,23 227:11249:18 oftentimes 254:7 oh 34:20 85:16 85:21256:11 264:17 275:15 okay 6:9 7:9,18 8:219:2,7,17 10:15 11:2,16 11:18 13:12,25 14:10 18:14,21 18:24 19:20 21:14 22:14,21 23:6,19 24:8 26:15 27:1,9 27:12 29:9 31:7 32:9,14 32:18 34:5 39:20 40:9,12 41:7,17 43:2 43:13,17 47:21 48:4 51:11 53:15,22,24 54:1,12,23 55:10,12 57:4 57:22 58:9 59:8 61:9 62:1 62:13 63:10,25 64:8 65:9 66:2 67:17 68:25 70:24 74:17,21 75:24 79:25 80:3,16 81:11 82:11 83:8 86:22 87:1,9 87:12,18 88:15 90:9,21,23 92:9 93:6,8 94:12,13 95:2 95:6,8,16,20 95:22 96:4,19 99:2,14 101:10 101:18,20 102:12,22 103:7 104:6 105:21 106:15 106:17 107:14 108:21 109:11 109:18,20 110:21 111:15 111:22 112:23 113:11,19 114:22 115:3,5 115:12,16,19 116:3 117:2,6 117:11,14,18 118:7,9,15,18 119:1 120:17 121:10,20 123:11,15 124:21 125:5 126:10,17 127:19 128:20 128:22 129:22 129:24 130:18 131:17,20,22 132:7 133:6,17 133:23 135:4 135:12 136:2 136:13 139:15 140:6 141:18 141:23 143:23 144:21 145:12 148:16 149:22 150:8,11,23 151:4,10,17 152:4 153:12 155:12 157:5 159:10 162:7 164:18,25 165:10,15,24 166:2 169:2,7 170:2,20 172:4 172:14,14 173:2,7 179:15 180:21 181:20 181:24 183:24 184:6 185:7,15 186:12,17 187:1,3,5 188:2,5,7,8 189:12,20 191:4 194:19 194:20,21 196:17,25 197:20 198:3 198:12,21,25 199:2 200:3,5 200:14,21 202:21,22 203:10 204:2,5 204:9,15,17 205:9,15 207:2 208:13,16,22 209:6 210:23 210:24 213:11 214:6,9 215:23 216:1,14 218:5 220:5,16 221:16,18 222:2,13,25 225:5,21227:5 227:25 228:7 233:18,21 234:15,17 235:10,17 242:24 245:17 247:2,24 253:16 254:16 254:23 255:11 255:16 257:1,4 257:10 260:11 260:20 261:14 262:5 263:2,14 272:2 277:12 280:6 old 54:25 75:6 on-going 36:15 50:2 once 70:25 165:5 165:10 182:14 183:20 234:6 261:22 267:17 one -by -one 185:16,17 ones 46:16 179:12,12,13 179:13,14 onions 39:24 onset 49:10 open 86:3 110:4 143:25 194:9 195:1224:11 267:8 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 25 opened 145:12 operate 74:6 operated 146:2,3 operation 34:6 opine 196:12 opinion 5:15 6:1 6:7 23:17 28:14,18,21,22 30:9 47:20,25 48:8,10 55:21 56:22 97:8,9 97:13,18,19,20 111:9 112:9,13 112:15,16,18 112:19,21,21 116:10,17,23 116:24 117:18 120:8,11,14,15 120:16,18 121:8 123:7,9 123:10,23,24 124:1,2 125:3 125:4 126:7,8 126:9,10,16 128:4,6,7 131:14,19,20 131:21 133:21 133:23 134:1,6 134:7 136:22 141:20 142:2 145:19 158:20 158:22,23 161:2,3,4 187:11 192:7,9 195:12,12 196:3 197:5 202:25 203:6 206:23,25 207:2,4,9,11 207:16,19 208:3,3,7,21 208:22 209:2,4 209:7,8,14 210:9 228:3,11 228:19 229:15 229:15,16,17 241:2 244:8 245:7,12 248:20,21 249:4,5,5,6,9 250:6,7,17,19 251:25 252:3,4 252:7 253:1,2 253:3,8,25 254:2,9 265:16 265:16,17 266:22 opinions 5:11 16:10 28:23,25 30:1144:7,7,8 97:7 117:22 128:8,10,18,19 128:21 133:22 134:4 138:6 161:7 162:21 195:10 opponent 105:8 opponents 217:17,21 220:19,25 opportunity 129:21 opposed 208:3 opposing 97:7 229:22 opposite 55:3 OPRAH 194:24 195:5,10,22,25 196:5,11203:2 opted 235:14 oral 46:18 92:22 102:7,10 131:3 orchestrated 45:3 order 12:14,20 14:4,23 15:5,7 15:8,14 39:21 52:21,25 78:2 85:25 110:4 137:2 138:22 270:15 orders 7:22 ordinance 211:20 212:2 original63:15 63:19 originals 24:16 24:17,19 ought273:7 ousted 202:14 outrage 197:14 outrageous 159:20 outside 121:23 121:25 122:1 131:6 owe 96:6 97:10 owned 86:12 103:15,20 200:25 ownership 201:2 owning 188:9 P.A 2:11,20 177:11,20 p.m 1:17 42:19 176:17 232:14 280:11 P2 263:3,4,6 page 3:3,11,17 52:14 178:3,14 178:20 181:12 181:13 235:25 242:12 283:4 pages 1:15 54:22 151:20 176:15 282:9 paid 156:12 229:16 255:16 262:2,6 painted 214:12 214:24 215:3,6 Palm 2:12,13 86:18 177:12 177:13 281:5 282:5 284:4,5 paper 21:13 30:22 106:20 116:15,22 162:10,14 papers 19:8 75:5 109:11 161:20 161:25 paragraph 84:11 103:13 186:10 186:20 187:7 207:7 210:1,19 214:7 234:16 236:1241:12 paragraphs 102:23 103:8,9 103:10,12 125:18 179:11 185:17 paralegal 157:5 157:9,14,18,19 157:20 paralegals 159:1 parallel 129:16 Pardon 74:22 93:18 103:1 145:23 241:22 255:3 276:6 parent 70:10 77:5 78:24 85:24 parent's 108:8 109:2 parents 106:4 107:24,24 Pariente's 208:18 park222:16 parking 211:20 211:21212:2 part 33:1135:19 40:9 43:25 45:12 46:24 85:12 134:8 192:1 193:18 215:16 237:3 243:18 264:25 partially 179:13 179:14 185:20 185:20 participated 162:1 particularly 109:3 parties 12:15 130:19 131:10 186:8 229:22 282:13 parties' 282:13 partner 34:23 150:14 153:5 153:22 154:15 party 117:18 170:16 232:16 244:2 party's 138:7 passed 8:21,23 86:5 passing 212:2 path 233:17 Patriot 141:1,2 Patsy 148:18 Paul 135:14 pay 34:1139:7,8 45:6 96:6 97:11 146:16 168:1214:19 215:14 229:19 255:11,13,14 257:14 258:25 payer257:24 paying 35:1 46:13,13 156:13 257:10 264:4 266:8 267:2 PC 76:17 80:18 80:23 pedophile 51:20 52:153:8,9 pending 14:14 15:3,21 16:6 18:8 26:8 30:1 30:3,5,7 41:21 48:6,23 52:11 65:2172:22 74:1181:19 82:5 83:2 92:5 92:12 107:1,8 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M. 107:15 108:3 110:19 119:15 121:4 124:19 141:13,18 168:12 211:17 212:20,22 230:9 236:16 236:16 238:10 255:2,5 259:5 267:20 269:16 269:22 271:19 273:10 274:6 275:17,25 Pennsylvania 70:7,8,15 73:24 74:2 78:5,9,10,23 78:24,25 80:19 80:19,25 81:7 81:24,25 83:11 85:10,11,14 86:6,7 104:12 109:12,22,23 109:24,25 110:6,10 111:16 people 16:19 17:17 35:5 36:1 51:10 78:14 131:5 136:20,23 137:18 138:7 142:25 144:25 147:25 148:24 148:25 149:17 155:7,8 161:9 187:22,23 248:8,11,16,17 249:18,21 252:18 253:12 253:23 254:1,5 274:2 people's 60:1 pepperoni 39:18 39:21,22 percent 143:8,9 143:12,13 perform 16:10 performed 16:12 period 23:23 43:11 147:22 205:11217:15 220:7,16 226:12 permanently 98:8 permission 274:22,23 279:19 permit 196:10 214:16 215:5 permitted 78:22 perpetrate 270:21 person 49:18 120:15 144:22 154:23 155:1 157:17 196:4 203:1209:20 224:25 252:16 268:23 person's 55:25 253:7 personal7:15 8:16 9:23 10:21 104:20 104:21 142:20 150:13 164:6 186:15 188:20 197:1,2,3 215:12 218:3 220:20 221:1 222:12 227:14 228:24 248:14 personally 8:19 29:14 131:17 168:4 184:20 191:17,20 214:1226:8,16 228:8 240:24 248:12 262:9 281:10 personnel 12:4 Peter 87:6 136:11,12,24 137:3 144:4 152:14 Philadelphia 70:3 96:5 97:10 102:13 103:15 phone 20:10 31:22 77:22 92:17 182:18 phones 78:15 275:11 phrase 8:14 138:11206:21 231:10 279:21 phrases 154:5,11 pick 125:19 128:12 135:24 picked 30:22 picture 212:6 piece 28:20 30:22 64:4,12 65:1,7 73:6 95:9 106:19 116:15,21 185:12 pieces 147:14 pill 233:10 PIPER 2:20 177:20 pizza 39:12,13 39:14,15,17 43:7 place 1:18 72:9 93:11 176:18 187:4 placed 25:5 216:24 Plaintiff 1:5,12 2:1 3:11 26:6 36:8 75:23 176:5,12 177:1 178:14 179:23 186:4,5,6 188:8 189:20 196:19,22 210:4,13 211:1 211:13,18 214:10,12,18 214:24 216:15 216:24 217:15 217:23 220:8 220:16 221:3 222:10,14 226:2,6 227:8 227:10 234:18 234:21235:16 242:14,21 246:4 Plaintiff s 174:21 179:8 186:18 187:6 210:3,23 211:21214:16 215:5 225:24 227:5 235:10 260:15 plane 19:12 planet 166:25 167:12,12 plans 232:10 Plantation 108:1 108:9 play 153:22 played 21:4 playing 221:23 221:23 plead 169:9 pleading 63:19 63:23 169:8,13 169:22 170:4 185:3 234:7 pleadings 4:13 35:1160:10,14 60:21,22 62:17 68:9 168:19,25 please 10:16 26:13 44:16 50:12 52:5,5,9 52:18 60:8 62:13 66:16 67:16 69:1,13 72:2 81:18 82:4 92:1,3 122:13 125:12 144:11 164:4 171:10 179:7 181:4 183:7 184:8,11,11 185:6 201:23 209:23 218:5 231:24 239:1 256:4,14 263:18 271:3,8 277:4,12 278:19 284:12 284:13 plural 127:7 point 31:5 33:13 47:12 52:19 63:19 77:7 110:12 140:19 156:16,17 180:10 182:5 182:22 209:9 212:6 222:20 233:25 police 140:10,21 235:12 policy 255:12 political 214:13 214:25 215:3,6 217:3,10,18,22 218:2 220:19 220:25 221:6 222:9,18 politically 211:22 212:4 politics 195:22 Port 98:8 101:4 101:21 136:19 136:21 142:24 190:9 191:22 191:25 192:1 192:21 193:15 193:22 portion 52:25 82:20,20,21,21 266:8 pose 80:1,4 position 37:24 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 27 49:24 51:18,20 51:22 67:1 75:21 78:2 88:17 104:7,8 129:21 179:22 268:17 273:6 positions 97:6 possession 151:14 possible 148:24 173:5 199:21 199:22 218:25 possibly 45:23 post 85:21 230:13 potential29:25 potentially 33:4 practice 65:24 67:2,22 69:12 69:20 72:18 73:10,16 75:11 76:9,11,20 77:4,22 78:20 78:23 79:10 83:14,15 85:2 85:16,19 88:8 89:2,9,22 90:1 90:13 108:23 112:2,5 113:6 115:8 168:11 195:8 224:22 269:20 practiced 5:22 practicing 3 5: 10 73:20 77:21 78:20 85:14,20 104:17,19 109:25 110:3 110:10 254:4 preclude 196:7 predicate 272:14 predictable 145:2 predicted 160:17 preface 69:16 76:7 prefer 63:15 129:6 preference 113:21 preparation 95:10 162:1 prepare 21:14 preparing 35:11 46:5 64:2 prerogative 125:16 233:5,6 presence 73:20 83:13 present 9:17 13:9 119:22 presented 70:4 272:24 pressed 266:23 267:1 pressure 242:14 242:21 presume 26:19 86:2196:17 127:1,2 165:14 186:16 188:17 188:19 pretend 269:9 270:12 pretty 145:1 253:11260:11 previous 129:4 principal23:9 23:10 principals 196:9 print 55:8 printed 54:5,17 54:24 261:19 printouts 93:24 prior 7:22 45:19 45:20 private 9:24 10:1 86:14 117:15 150:1 158:10 199:10 201:4 privilege 20:5 38:2 133:19 134:15,18 154:17 164:24 165:15 166:13 173:21,23 180:7,8,18,20 224:9 privileged 24:4,8 24:1126:3 43:20 47:17 96:21,22 118:1 133:5,13,14,16 150:2,21 152:18,22 153:1 164:18 164:21,23 167:2,8 170:21 173:17 247:19 privity 179:10 pro 2:2 84:1 177:2 probably 31:14 56:19 60:7 89:22 160:3,5 186:10 245:19 245:20 261:3 problem 31:7,9 86:7 problems 189:6 procedure 100:4 203:5 proceed 44:11 49:22 114:3 254:20 proceeding 105:20 150:10 235:7 236:20 236:25 237:4 proceedings 8:5 20:14 28:8 42:13 52:12 64:25 72:6 81:20 82:6 83:3 92:6,13 107:2,9,16 108:4 113:24 114:6 121:5 132:22 171:14 174:11 179:1 218:14 251:1 254:14 279:17 proceeds 23:7 process 97:3 172:24 272:17 processors 253:19 produce 100:19 195:22 229:12 product 4:14,15 5:1,5,7,19,19 7:19 12:3 15:21,25 16:6 16:11,16,21 17:4,12,13 18:11 19:21 25:24 26:2 29:22,24 30:12 31:8 33:2 43:20 44:5,6,9 60:17 93:22,23 96:14,15 97:4 97:12,25 101:19 104:23 105:11,14 112:10 128:1 137:2 147:10 152:19 168:19 173:17 191:24 194:3,4,6,12 194:13,16,18 197:3 204:21 204:24 209:17 222:22 226:20 240:20 245:15 247:13,14,21 249:7 250:5,15 profess 195:25 professed 265:3 professional 83:11277:8,20 prolific 243:24 pronounced 126:19 proof 144:9 propaganda 221:13 property 103:15 199:9,10 267:4 proposed 91:9 prosecuting 142:12 protected 122:1 122:3 214:11 214:21217:16 220:8,17,22 225:25 242:12 242:18 provide 37:13 99:19 210:10 210:10 228:3,3 234:6 245:14 provided 19:22 37:10 40:19 62:8 67:10 271:3 provides 23:2 providing 267:13 provision 196:6 prudent 124:15 270:11 public 17:8 24:6 25:4,16 30:14 31:5,12 32:23 33:16 35:13 43:19,20,25 45:146:9,18 57:7 68:20 69:24 86:17 93:23 111:5 122:2 130:14 131:2 134:17 134:19 137:11 140:11 149:4 166:3,4 189:21 189:23 190:1,1 190:8 191:6,10 192:3,18,22 193:2,16,20 194:7,8,22,25 195:1,2,4,6,14 195:20 196:20 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 w 196:23 197:7,8 197:15 199:11 202:23 203:12 205:16 207:8 208:25 210:3,6 210:8,15,17,23 211:3 227:22 228:7 230:3 231:21233:13 234:4,20 236:23 237:21 239:9,10 249:18,19 251:18,23 252:14 253:12 253:19,23 264:14,20 265:5,11,25 266:12 269:1 273:20,25 281:9,22 publicly 197:11 published 128:23 pull 14:3 pulling 64:10 purported 33:14 purporting 70:1 purports 76:1 90:19 purpose 59:14 227:7,16 249:20 purposes 33:17 251:23,24 pursuant 127:12 put 19:9 67:22 92:18 103:12 110:9 119:25 131:1 138:22 142:15 165:11 173:15 195:17 206:10 259:19 268:16 278:1 279:6 putting 64:11 184:9 Q Qualifications 202:11 qualified 169:10 169:14,16 quantitative 207:10 quarter279:11 question 5:13 6:4 9:6 11:1 20:8,16 22:11 26:8,14 30:21 32:4,1133:25 34:4 41:1,14 41:20,21,23 43:4,24 44:16 47:19 48:6,23 51:2152:11 55:13 58:23 60:5 62:13,22 62:23 64:14,18 65:2166:16 68:13,16 69:3 69:5,15 71:21 72:21,22 74:24 76:5 80:15 81:17,19,22 82:3,5 83:2 91:25 92:1,4,5 92:10,12 94:24 99:24 100:16 100:24 105:10 107:1,8,14,15 108:3 109:7 110:21 120:24 121:1,4,17 122:19,21 123:2 124:10 124:11,19 125:2,10,13 139:15 164:4 165:22 167:23 168:12,13 169:2,20 171:1 171:5 172:19 179:17,17 182:11 194:15 194:19 213:8 230:8,10,13,18 231:6,7,8,10 238:10,24 239:12 255:2,5 259:5 267:20 268:13 269:16 269:22 271:9 271:19 273:9 275:17,24,25 276:2,7 277:3 277:14,20,23 questioning 8:4 93:15 99:17 129:18 212:19 questions 3:16 6:8,13 10:8,10 26:10,1143:14 52:18 54:11 79:19 88:2 98:13 99:18 104:1 106:12 108:10 115:17 124:18 129:5 129:12 178:19 205:3 212:17 212:24 219:11 232:20 242:1 244:23 quick 43:4 quickly 210:22 quiet 185:2 quite 8:6 23:21 37:7,7 96:2 249:6 250:14 quote 138:21 145:10 quoted 155:17 R racketeer271:16 271:21272:22 Racquet 223:1 Raider 247:14 264:5,17,22 raise 109:11,14 raised 5:4 68:23 ramifications 163:12 ran 38:20 184:24 Randolph 148:18 171:19 172:16,23 212:14 213:5 232:7 range 11:21 167:21 rate 156:5,15 158:2,14 159:13,14,16 159:17 276:25 rates 158:5,11 158:25 159:22 Raton 1:20 9:12 176:20 react209:11 250:6 reaction 196:13 197:9 236:18 248:8,14 249:17 read 4:13 6:9 17:24 33:8 52:2,6,12 53:13 54:24 71:24 81:12,17 82:3,19,23 84:10,11,16 85:23 92:3 103:3 106:12 106:18,19,21 106:23 107:2,9 107:16 108:4 121:5 124:17 136:18,21 140:10 143:6,6 143:7,9,14 160:8,13 169:1 179:19 180:2 184:21 185:2 189:2,9,10 190:6,25 191:5 193:1,10,11,22 194:2 197:13 203:1,2,18 204:15,17,25 205:2 206:1,9 208:21215:15 216:11227:15 238:17,20,25 241:5 246:17 247:3 254:25 259:16,24 265:7 266:25 269:2 280:2,3 284:12 reading 21:12 56:18 76:15 84:18 98:16,17 98:22 129:8 140:9,21 184:6 185:3 204:18 204:23 206:20 215:19,21 ready 80:14 114:3 175:5,6 220:5 241:19 254:15 real 35:4 36:9 207:21265:22 265:23 267:12 270:11,12 275:9 realize 261:2 realized 69:22 really 35:14 46:16 50:23 54:8 85:22 118:2 155:21 158:22 159:3,5 174:3 184:21 221:14 262:24 265:21279:2 reason 44:3 166:23 202:22 221:20 reasonable 124:15 recall 18:20,21 18:23,24 19:2 33:9 67:8 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 29 73:19 77:1 78:2179:18 81:5 84:6,6 88:5 92:20 93:1,4 101:16 136:22 140:9 169:11200:13 215:25 249:11 recalling 40:3 131:9 receive 56:6 105:22 106:6 228:14 received 37:21 107:4,5,6 receiving 55:25 recess 20:11,13 28:7 42:12,24 43:5 72:5 113:23 114:5 132:21 171:13 218:13 254:13 279:16 recipient 46:22 reciprocate 71:19 reciprocated 71:15 recite 58:25 67:7 112:10 recited 43:23 78:6,17 recites 17:18 reciting 16:24 reckless 91:5 248:10 recognize 148:17 148:19 149:2 188:16 recognized 78:3 recollection 38:22 39:5,6 40:7,14 74:13 80:24 91:8 94:16 103:23 104:2,11 119:16 127:20 147:8 170:4 202:3,9 216:4 227:2 record 12:19 17:8 20:19,19 25:4 29:3 30:15 31:6,12 33:12 39:2,3,3 41:13 42:8,10 42:10,15 44:1 45:8 52:3 53:4 57:25 69:24,24 71:25 72:4 87:23 91:11,24 93:23 99:16 110:9 114:8,14 122:11 130:15 131:2 132:23 134:19 137:11 137:17 138:23 139:1 140:11 143:13 144:5 151:8 171:15 174:9,10 189:21 194:7 195:5 197:15 218:8,21 234:22 235:4,4 244:15 269:1 273:20,25 278:1279:6,15 282:9 records 11:20,23 13:6,8,1124:6 25:16 26:16 33:17 35:13 45:146:10,12 46:18 57:8 73:25 94:20 134:17 189:23 190:1,8 191:6 191:10 192:3 192:13,18,23 192:23 193:2 193:17,20 194:8,22,23,25 195:1,2,6,14 195:20,22 196:20,23 197:7,9 199:24 201:25 202:23 203:12 205:9 205:16 206:4 207:8 208:14 208:17,25 210:3,7,8,15 210:17,24 211:3 227:22 228:7 231:2,4 231:21233:13 234:5,21 237:21239:9 239:10 243:24 251:6,18,23 252:14,23 253:12,19,24 257:20 264:14 264:20 265:6,6 265:11,25 266:12 271:3 recuse 138:20 red 59:21 redact 17:9 redacted 16:24 25:2 redacts 17:8 refer 271:15 reference 61:19 62:5 82:12,13 104:13 110:14 134:25 138:18 138:21 193:2 251:11 referenced 87:24 141:16 referred 83:25 271:21272:2 referring 30:16 63:7 98:3 129:9 169:12 189:15 198:16 217:19 224:24 235:5,8 237:8 238:16 242:23 248:16 250:23 refers 169:13 reflect 23:22 218:8 refresh 39:5 94:16 127:20 refreshed 103:22 104:2,11 refreshing 91:7 refund 262:3 refusal 99:19 refused 37:14,18 regard 4:14 5:3 15:21 17:14 18:6,11 19:10 48:149:24 56:14 87:24 88:4 104:8 138:2,2 141:14 147:11 150:18 151:24 166:10 168:21 188:14 207:7 221:2 223:24 224:6 240:21242:18 245:5 250:10 250:14 251:12 regarding 7:23 10:22 14:23 36:2137:17 72:17 73:19 90:1 97:2 99:17 103:25 108:22 111:25 208:18 222:21 226:20 246:20 259:25 272:19 regardless 11:1 96:6 97:11 238:4 regards 189:9 registered 70:1 80:19,25 81:3 registration 103:20 regular 83:12 regularly 37:3 199:13 regulating 57:2 127:13 241:5 relate 25:22 102:20 228:23 228:24 related 37:25 43:9 142:8 147:6 188:23 193:13 211:14 212:19 213:6 250:12 relates 225:25 relating 38:10 relative 7:23 81:3 282:12,13 relatively 187:8 relatives 81:8,25 relay 229:2 released 40:25 relevance 8:5 66:19 relevant 15:2 66:4 231:22 233:16 reliable 250:25 relying 59:4,5,8 59:1160:8,10 60:18 138:1,5 138:6 remember 19:14 19:15 31:13 33:6,20 34:5 50:22 51:9,9 51:11,12,15 62:163:12,16 64:2,5,9,10 65:10 68:21 86:9,10 88:16 88:18,19 89:25 92:24 93:12 95:19,2196:24 97:22 102:4,5 102:9,10 104:2 104:9,13 135:24 139:15 140:21 141:7 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 30 141:10,16 148:1 149:1,25 150:12,13 153:9,10 156:7 156:14 164:10 164:10 167:21 169:9,10 189:4 197:19 212:5,7 215:18,19,21 215:22 216:1,7 221:14 224:13 225:6,6,8 226:22 232:7 243:6 244:13 244:15 246:5 263:1273:14 remembering 39:2 122:7 216:11224:5 remind 7:22 12:14 remodeling 189:16 removal 217:2,8 222:7 remove 218:1 221:5 removed 199:1 200:18 217:1,7 222:9 renew 10 1: 14 129:4 repeat 72:25 91:24 repeated 124:5 repeatedly 124:17 274:14 report 31:23 56:15,20 57:3 88:22 115:19 122:8 123:7,15 140:11,21 149:14 237:23 239:6,18 240:10 241:7 282:8 reported 78:10 89:2,5 reporter 1:23 12:18 20:11 28:4 31:16 43:10 52:16,25 53:5 67:25 68:3 72:4 81:14 82:2 92:2 99:21 113:20,22 114:13,15 121:2 123:4 132:24 171:11 171:17 174:8 174:25 175:6 176:23 179:3,8 201:20 205:5 209:22 218:7 233:20 241:10 241:15 254:10 260:14 273:11 278:2,4 279:4 279:14,18 281:8,16 282:1 282:7,19 284:18 reporter's 277:17 reporters 138:6 Reporting 1:18 1:23 128:24 176:18,23 281:17 282:21 284:13,19 reports 194:2 197:13 represent 46:11 75:21,22 79:16 151:6 201:3 229:22 representation 60:19 167:14 167:17 192:1 228:23 229:2 256:6 257:11 representations 110:5,8 represented 85:9 119:14,20 152:24 180:17 200:19 202:7 202:19 277:11 representing 40:2146:10 142:13 159:19 160:6 263:8 represents 150:25 151:2 request 46:18 52:24 93:17 98:15 195:4,14 201:22 214:16 215:5 217:2,9 228:12 230:3 230:15 231:2,4 231:21241:13 243:24,25 264:12 266:12 275:19 requested 282:9 requesting 267:25 requestor 228:9 requests 33:17 35:13 45:2 46:19,23 91:16 189:23 190:8 191:10 192:18 192:23 193:17 193:20 194:8 197:23 199:24 200:1,10 201:25 203:12 205:10,16 206:4 207:8,21 207:23 208:14 209:10 210:4,8 210:24 233:13 234:5 251:18 251:23 252:9 252:14,24 253:12,19,24 254:2 264:7,8 264:14,18 265:6,7,8,9,25 266:4 270:14 270:15 required 56:12 85:13 requires 133:4 research 29:23 96:17 97:4,23 230:23 researched 18:3 reserves 246:2 reside 101:21 resided 70:8,13 84:24 98:8 residence 70:9 107:18 109:13 residency 82:20 resident 136:18 136:19 148:21 173:9 188:8,13 188:25 246:4 residential 81:4 103:15 residents 96:5 97:10 187:9,12 187:15,19,22 187:25 246:1 residing 110:10 resolve 131:5 resolved 173:1 respect 14:5 71:6,7,8,9,13 71:15 179:22 214:11,22 230:25 231:1 233:12 234:20 respond 104:1 185:21 responded 187:1 responding 171:8,9 response 91:12 211:21217:23 230:5,5,6 235:10 responsible 143:19 restate 62:13 restricted 14:17 14:22 restrictions 142:15 restroom 41:25 42:4 113:13 rests 95:9 result 20:2145:5 96:16 97:4 214:15 215:4 222:7 237:22 247:2 249:6 264:20 resumed 175:8 retained 133:9 retaliation 13:19 14:13,18 268:8 retired 200:17 retract 36:22 retracted 139:1 139:7 retrieved 69:17 return 172:22 returned 38:4 reveal 166:19 revenue 159:21 review 23:19,20 282:8 reviewed 25:2 25:10 162:3,4 162:5 211:24 250:4 reviewing 79:23 135:7,10 Richman 161:25 Richmond 37:13 37:14,17,19 47:2 95:18 96:1244:12 RICO 27:8 94:19 95:8 134:8 161:20 161:22 162:6 243:2,5,21 245:9 246:13 251:6 254:21 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 31 272:12 right 9:3 11:6 60:8,23 62:10 62:15 84:17 89:1 102:8 106:16 108:17 110:12 115:16 118:4 122:7 124:2,2,7,16 128:13 130:3 132:1,9 141:19 145:3,12 153:1 153:13 154:3 159:8,11 165:25 168:25 169:19 183:1 191:20 193:13 196:16 199:11 202:13,24 203:3,4 206:4 210:5 212:16 214:8,20 219:14,21 220:15 222:7 223:15 224:1 227:10 232:22 241:4,21,23 246:21261:17 263:10,11 268:24 278:5 279:21280:2 rights 142:16 189:22 190:5 191:9 193:5,7 193:8,9,9,12 210:6,14,15,17 215:10,11 227:18 ring 34:22 36:3 36:4 37:22,24 38:15 49:25 51:16 114:20 116:3 rip 181:6 Robert 1:7,11 2:9 3:3 4:2,10 176:7,11 177:9 178:3 179:5 186:6 257:8,11 281:10 282:8 284:6 roboca11253:19 roles 21:3 Rolling 214:8 room 224:14 rotten 253:11 routinely 168:1 rubric 85:12 rule 63:21203:4 ruled 212:21 rules 56:12,16 57:2 58:10,13 58:15,16,21,25 88:22,25 122:9 123:8 125:21 126:5,11,13,16 127:13 241:5 ruling 210:11 run 86:6 110:6 112:6 216:16 216:20 runner 37:5 266:8 running 35:5,10 35:18 36:25 85:24 267:3 ruse 51:19 Russell 34:23 S sad 268:15,15 273:5 safe 63:23 258:6 safely 121:18 Saffron 146:4,5 146:5,20,22 147:2,24 148:4 sake 179:10 salt 259:12 260:8 sanctions 79:5,9 79:13 sand 199:3,20 Sarah 225:9,10 satisfy 218:12 save 100:11 146:14 savvy 50:7 saw 74:18 84:8 87:23,23 88:21 169:8 206:16 217:5,20,21 254:24 255:1 259:21260:9 261:3,3 265:19 266:13,14,14 266:19 saying 14:16,21 31:13,14 35:17 43:18 46:6,10 46:11,20 47:4 48:25 52:19 57:23 64:11,11 65:23 71:13,17 71:18 72:13 75:3,1176:19 76:23 81:9,15 84:7 85:1 89:17 90:3 91:15,16,19,21 97:198:7,22 119:13 120:19 120:23 138:3 155:18 161:24 162:2 163:3,7 182:19 183:2 191:1 192:12 199:2 204:4 219:18 237:2 242:25 245:8 246:21247:20 247:23 250:24 252:22 272:21 says 36:5 59:20 59:20,21,21 72:176:24 97:17 103:10 103:14 111:4 127:6,10 130:19 152:9 155:20 180:1 188:19 191:8 193:4,14 205:15 209:7,8 210:13 211:7 215:16 231:14 259:3,8,9,11 scanner 251:19 scepticism 143:10 schedule 182:23 232:7 scheme 36:7,16 76:5 163:8,11 208:24 243:18 265:19 266:11 267:4,15 269:6 270:21272:10 272:17 274:14 schemes 252:5 school 5:21,22 6:21,22 7:1,2 105:21,23,25 106:7 107:6,12 107:20,25 108:7,24 109:1 110:1 156:19 157:16,20 223:17 268:19 scope 21:16 166:2,22 167:13,17 Scott 1:8 2:11 176:8 177:11 234:22 284:4 screen 55:4,7 se 2:2 177:2 search 148:11 season 187:24 seasoned 158:16 seat 216:16,20 222:18 seated 186:14 second 2:12 3:12 47:19 93:15 157:14 167:7 173:1 174:14 177:12 179:4 181:9 186:4,17 187:2,7,14 211:8,10 220:14 231:22 244:9 seconds 168:22 218:5 secrecy 165:16 secretary 34:23 35:16 secretary's 34:24 see 7:7,12 8:14 8:21 19:23 28:150:12 51:6 54:5 57:24 58:4 61:19 63:15,18 63:22 64:6,18 64:20 67:24 74:14,20 75:4 78:17 80:22,23 84:2,12,17 87:3 88:16 93:11,24 94:2 94:5 96:23 98:20 99:8 101:11 113:17 115:17 127:2 127:20 128:11 129:9 135:3,5 135:17 137:18 137:22 138:22 138:22 144:22 144:25 147:12 148:6,10 150:8 150:11 156:9 158:5 160:5 161:17 165:14 168:3 169:15 170:20 181:1,3 181:7 182:1,1 184:12 186:25 188:18 190:7 190:18 192:2 193:1,16 199:22 202:21 213:23 221:17 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 32 225:19 239:1 255:20 263:18 265:22,23 270:20 275:15 275:19,22 seeing 19:3 75:8 102:19,21 212:6 230:22 seek 79:9,12 258:12,16 seen 18:15,18,19 18:21 19:15,18 25:6 26:22 61:10 64:4,13 65:2,7 73:7 92:25 127:21 141:2,3 144:24 158:24 187:18 188:15,17,23 199:23 205:23 206:1210:11 215:2 226:23 226:25 227:1 246:5 send 126:17,23 146:22 147:2,5 147:12,14 152:14 sending 129:1 252:14 sends 24:24 sense 230:15 251:5,15 sent 47:8 49:23 50:14 53:12 146:25 152:17 246:10 247:18 247:22 260:25 261:20,25 sentence 162:23 184:22 226:10 sentences 188:6 sentencing 185:16 separate 66:18 separately 13:16 September 116:3 117:6,7 119:11,12 123:11,16 130:2,5,8 131:12 163:16 163:19 164:1,2 243:9,13 series 88:2 104:1 serious 271:7 served 58:18 172:23 251:18 service 172:18 172:23 services 24:22 264:5 set 34:20 67:3,4 68:8 78:1 98:17 179:21 179:23 232:18 267:6 setting 131:7 159:5 settle 132:16 settled 214:17 215:13 settlement 116:5 117:15 121:23 130:20,25 131:4,4 180:2 181:13 215:15 215:20,21,23 216:1262:15 settling 274:21 setup 46:3,8 seven 106:12,16 186:22,25 187:1,2,7 218:11219:20 219:24 277:5 277:14,24 278:19,23 seven -fifty 187:21 sevens 186:21,21 seventeen 225:20,21 shake 269:5 sham 36:9 shame 232:10 share 7:9 150:3 150:15 249:7 252:8 shared 131:11 she'll 172:3 182:8 sheet283:1 284:13,14 Sheila 223:11 224:7 sheriffs 199:17 shit 64:4,12 65:1 65:7 73:6 short 261:11 shorten 216:12 shortest 125:19 shortly 41:25 shot 44:20 45:14 46:24 270:14 shots 33:20,21 34:15 45:18,24 46:15 253:24 264:7 269:4 show 13:5,8 14:1 15:5,7 17:23 27:20 58:7 84:14 86:8 94:15 98:15 129:6 134:24 168:24,25 182:2 183:18 183:18,19,19 showed 21:5 37:14 78:8,9 showing 109:12 shown 104:10 shows 51:7 183:9,12,13 265:23 shut251:19 252:11 side 68:2 222:16 238:5 278:22 sign 27:16 74:17 75:6 199:15,15 199:16,19,22 199:23 218:1 221:5 222:21 284:12 signed 57:22,25 58:1,6 74:19 74:21,23 75:1 75:2,7,8 117:9 130:10 281:13 signing 75:6 signs 199:2,7,9 199:17 216:24 217:1,3,5,6,8,9 217:17,20,21 218:1220:18 220:23 221:5 222:8,9 226:2 226:17 silver 144:15 145:14 198:4 198:13 simplify 70:2 Sincerely 284:16 single 172:15 272:8 Singular 139:20 sir 7:1124:12 44:10 67:19 119:18 245:18 sit23:1 101:15 111:19 148:9 148:13 190:11 229:10 258:1 269:9,14 sitting 67:25 68:2186:9,10 86:23 138:3 148:20 206:19 268:24 situation 110:2 six 27:19 28:3 95:23 268:1 278:10 sixty 168:22 197:25 252:23 264:18 265:8 sky 18:16 19:5 141:9 slander 10:22 18:5 25:22 94:21 110:22 156:20,25 157:2 268:6 slandered 10:9 66:5 156:25 slice 39:11,15,16 slowed 106:2 slowly 106:21,23 small 147:21,22 158:9 187:8,11 259:1 smaller 8:12 smells 253:11 smiley 239:1 smoke 267:17 smoking 267:19 soapbox273:3 sober 145:13,25 146:1,2,3 social224:19,21 225:2 socially 29:14 society 155:19 252:19 sole 153:10 solely 166:3 somebody 28:19 88:22 192:12 192:14 someone's 106:9 248:11 somewhat 206:20 son 31:25 34:19 35:6,6 62:19 65:5,24 85:9 94:11 168:10 170:9,9 229:20 236:3,15 237:10,14,16 241:6 267:6 268:16,17,18 268:19 269:19 270:6,11,22,23 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 33 son's 33:19 34:16 35:25 44:13 45:22 270:16 son-in-law 12:24 13:9 15:1,2,18 sooner 104:11 sorry 4:24 5:15 10:19 28:4 30:16 41:18 58:12 64:6 89:4 115:23 116:12 133:10 145:14 161:14 184:22 186:24 196:17 199:3 212:15 236:20 256:4,5,20 267:24 268:24 270:23 sort 199:7 Sosa 87:6 sought 73:14 79:4,5 sound 61:11 159:8,11 165:25 212:16 sounds 97:18,19 110:23 230:16 south 199:4 Southern 1:1 176:1 186:14 space 87:6,7,7 spaghetti 128:11 128:13 speak 102:3 138:1 143:14 149:14,16 150:17 168:24 202:8 211:20 241:5 248:9 256:4 speaker 173:16 speaking 12:21 12:21 102:4,5 102:9 146:13 256:21 speaks 41:13 76:22 83:18 85:4 127:15 209:2 260:22 Spechler 200:23 200:25 202:12 202:12,20 205:7 Spechler's 201:5 special 133:3 241:8 specific 58:23,24 63:7 98:14 102:20 227:9 specifically 16:1 96:25 98:17 102:6,8 197:16 197:17 specificity 62:2 specifics 15:1 262:25 specified 23:23 specify 102:19 speculate 105:17 105:19 145:17 170:23 209:20 speculating 22:19 145:21 145:24 200:12 209:13 248:6 257:22 speculation 230:24 276:13 276:17 speculative 257:15,16 speech 52:23 214:11,22 217:16 218:2 220:9,17,22 221:6 225:25 227:6,12 242:12,18 268:3,10 spell 126:19 spend 223:19 spent 134:25 237:14 240:8 spoke 32:18 38:25 87:14,16 87:16 89:7 97:23 117:7 123:12 130:9 146:20 153:2 210:22 spoken 49:14 87:12 146:6 148:23 197:6 235:21236:8 sponsor 85:25 sponsoring 70:11 spoon 128:14,15 128:16 Spotlight 219:5 spousal 224:9 Springs 1:25 176:25 281:19 282:22 284:20 squared 263:2 SS 281:5 282:4 stack 45:16 staff 17:15 38:12 121:13,14 122:4 139:12 153:2 staffs 15:20 standing 99:16 standpoint 29:21 197:3 star 21:5 274:19 start 6:217:1 83:23,24 106:15 113:2 184:6 185:15 186:25 232:14 started 40:1 186:10 278:5 starting 12:10 131:24 201:20 219:25 241:24 starts 267:23 starving 108:19 Stat211:19 state 33:16 34:13,14 46:9 56:4 74:7 83:13 84:23 85:15 89:17 99:15 142:24 159:2 186:13 190:9 191:13 192:4,19,20,21 192:23 193:7 193:20 195:21 196:9 234:19 235:2 240:2,18 243:24 253:20 264:12 265:11 266:3,5 267:5 270:20 273:23 275:20 281:4,9 281:22 282:4 stated 88:7 94:18 135:20 163:2 234:22 235:3 236:23 statement 30:14 30:16,23 31:1 31:10,1132:20 32:22,25 33:6 33:8 34:10 37:1138:8,10 38:23,25 39:4 39:5 40:3,5 42:3,5,2143:9 43:10,12,13,17 43:19 44:4 52:3 59:3 60:4 61:23 62:8 65:11,15 68:5 70:22 76:13 83:17 96:5,20 96:23 97:2 98:6,11 110:2 116:11 129:11 138:4 139:4 171:7,10 187:19 207:6 221:2 227:23 240:13,14 248:25 250:11 265:1266:2,9 274:14,25 statement's 60:7 statements 23:2 23:19,20,22,24 23:25 30:17 40:160:18 68:9,20 76:10 96:11,14 97:6 98:14 116:12 129:6 138:17 139:16 150:11 152:20 160:4 197:14 239:23 243:23 266:24 271:7 STATES 1:1 176:1 status 253:21 statute 163:9 210:5,14 272:11 statutory 189:22 190:5 191:9 193:5,8,9 203:4 227:10 stay 182:23 218:22 232:17 stenographic 282:10 stenographica... 282:8 step 129:19,20 steps 61:21 stick39:23 216:6 stolen 47:22 stood 30:21 stop 68:17,18,25 69:2 185:9 186:9 199:5,6 stopped 225:16 stops 9:4 straightforward 63:2 Stream 2:18 4:11 15:19 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 34 18:9 20:24 21:10 24:5,14 24:21,25 26:6 26:15,17 28:25 30:2,4,6,8 56:1 56:3 57:9 61:4 61:6,8 62:19 63:20 70:9,14 74:3 78:11 84:25 111:6 119:10 121:21 127:12 133:3 133:22 138:18 141:1,2 148:22 154:13 158:2 159:19 160:6 165:24 167:25 173:10 177:18 179:6 186:7,13 188:10 191:14 192:20 193:20 197:18 206:24 209:11,11 214:13,25 216:16,21 217:1,6,7 223:1,9,17 226:17,18 228:1,9 229:10 229:16,18 244:17 248:3 249:22 250:8 260:25 261:2,4 261:24,25 262:2,6,9,11 262:14,17,19 263:13 264:10 264:10,13 265:5,20,25 266:13 268:19 270:19 Street 102:13 103:14 108:1 111:15 strictly 120:17 123:25 strike 6:16 48:12 52:5,9 54:10 65:19 82:25 94:14 136:8 168:14 171:6 230:11231:11 231:16 239:3 245:21271:19 274:9 276:3,15 276:18 study 112:22 stuff 249:15 style 284:11 styled 4:9 subject38:7 50:1 97:22 111:24 127:4 142:2,21212:3 234:10 subjects 161:7 submit 24:20,21 56:9 205:10 submits 194:8 submitted 25:17 189:23 190:7 190:15,16 191:9 192:19 193:16,19,24 203:12 205:16 205:22 209:10 submitting 207:7 subpoena 173:9 182:2 183:16 184:2 subscribed 283:22 subsequently 138:19,19,25 139:6 216:17 216:22 substitute 180:22 subtract 23:6 successfully 260:2 sucked 245:9 sue 168:4 195:6 195:13,21 221:21 sued 18:9 37:18 38:5 95:4 136:20 137:19 192:14 sues 186:6 suffers 252:20 sufficient 89:12 232:21 suggest 100:16 100:22 suggested 74:1 suggesting 247:19 suggests 90:19 suing 18:5 94:22 95:2,6 suit 10:22 36:10 40:2194:19,21 95:8,9 134:8 161:20,22 212:9,10,11,13 213:13 243:5 243:21245:9 246:13,14 247:11254:21 255:25 261:12 261:13,14 262:17,20,21 262:22 263:9 Suite 1:19,24 2:21 176:19,24 177:21281:18 282:22 suits 27:1,3 94:20 sum 215:15 summer 136:3,4 223:8 Sunrise 2:21 177:21 Sunshine 212:8 212:10,11,12 212:13 213:7 255:25 256:7 256:12 257:4 258:11261:12 261:13 263:9 support 66:25 190:3,3 supporter 189:20,25 196:19,23,24 197:7,8,21 198:2 supporting 267:11 supposed 70:11 70:13 73:23 109:23 152:9 171:19 183:13 183:18 218:10 232:8,8,13 240:10 268:25 Supreme 74:5 200:18 208:17 252:2 sure 8:3,7 13:3 13:16 22:25 26:20 28:6 33:7 34:9 39:15,16 47:3 51:7 62:14,16 68:4,18 88:3 92:10,17 100:3 118:3 121:13 124:7 136:13 139:18 144:13 157:8 168:8 171:12 179:20 181:5 182:9 191:17 204:10 213:1,23 218:6 264:2 surprised 168:7 265:13 surrounding 199:2,7 202:1 suspect 179:24 swear 59:17 Sweetapple 1:7 1:112:9 3:3 4:2,8,10 7:18 12:10,12 13:19 14:8 20:23 43:15 72:8 81:12 82:3 83:9 92:3,11 98:19 99:5 101:2 114:18 122:17 123:6 133:2 144:15 145:13,14 156:20 176:7 176:11 177:9 178:3 179:3,5 179:10 181:4 181:16 183:9 183:23 184:5 185:6 186:6,7 186:9 231:1 233:23 235:12 256:20 257:8 257:11260:18 263:6,7,8 268:3,14 279:7 279:22 280:1 281:10 282:8 284:6,7 Sweetapple's 12:24 13:9 71:3 182:12 205:2 swore 98:7 275:1 sworn 4:3 40:5 42:3,20 43:9 43:10,12,13,17 59:3 61:23 156:18,19 240:14 281:11 283:22 system 22:21,23 22:24,24,25 table 64:3,11 take 4:9 18:6 23:6,11,12,13 25:23 26:2 28:4 39:16 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 35 42:4,20 43:13 61:21,2171:22 75:2197:6 113:2,16 125:5 125:7,13 129:21 131:24 132:6,8 134:24 135:2 159:24 164:7 168:2,22 170:6 171:11 175:4 179:20 191:16 198:10 205:14 217:19 218:7 230:14 233:9 254:10 254:11259:12 280:5,6 taken 1:12,16,22 20:13 28:7 30:17 42:12 72:5 113:23 114:5 132:21 154:2 171:13 176:12,16,22 218:13 254:13 279:16 284:7 284:11 Takes 42:9 talented 157:17 talk 17:19 41:3,5 49:12 66:22 76:11 113:17 128:22 163:15 163:20,21,23 163:24 224:11 233:15 272:23 talked 18:2 21:21 103:17 130:11 141:8 talking 23:24 32:20 40:5 46:5,7 50:13 50:24 62:12,25 72:11 82:18 86:16 94:6,8 103:9 110:18 117:17 149:5 151:19 157:10 157:13 163:18 168:9,9 173:24 191:20 224:11 224:25 233:13 243:3 269:8 272:12 273:13 talks 43:17 45:13,18 223:22 tally 205:12 tap 275:11 taped 33:3 target 207:20 254:1270:19 targeted 217:2,8 targeting 35:12 35:20 265:4 tax 86:18,18 96:6 97:11 257:24 Taylor 144:3 team 96:1 telephone 47:9 146:20 173:14 tell 6:10 12:3 19:2126:16 29:16 31:13 33:5 40:16 43:4 44:9 55:2161:9 66:3 69:11 72:2177:23 86:23 89:19 97:6,22 109:24 113:1 133:12 143:23,23 144:11 149:21 179:12 182:6 182:12 190:25 191:15,19,22 207:24 209:18 224:5 230:16 239:6 245:18 259:20 262:19 269:12 271:1,6 271:8 275:22 277:4 telling 21:21 23:2 38:22 51:22,24 56:24 60:13,17 97:5 105:13 123:1 144:12 191:12 204:23 237:22 tells 85:15 143:3 223:23 templet 266:17 ten 9:19 49:15 54:4 103:13 170:7 209:10 210:3 218:5 253:18,18 266:18,21 ten -and -a -half 9:19 tenant 87:3,4 tennis 150:14 152:23 153:5 153:21,22 154:3,15 223:1 tense 276:11 term 34:22 44:2160:23 95:13 118:4 169:14 205:4 249:11 terms 4:16 52:15 104:24 154:9 155:7 160:3 163:10 164:24 240:12,12 243:10 247:5 terrorism 251:12 251:14,25 terrorist 251:8 263:14,20 terrorizing 251:16,21 testified 4:3 266:7 275:1,16 testify 5:11 testifying 18:1 145:4 testimony 61:20 77:25 91:18,25 125:8 127:3 153:20 211:25 215:11238:15 238:19,21 241:13 251:17 274:4 thank 8:7 48:11 52:20,22 62:16 63:10 67:14 83:8 100:25 104:11 114:16 129:23 180:11 185:8 189:19 203:10 238:8 241:13 248:22 248:24 268:1 279:24 Thanksgiving 276:23 theirs 202:9 theories 229:20 272:25 thing 37:5 40:2 102:20 124:15 185:13 204:7 226:19 260:5 268:16,23 269:24 things 6:7 7:18 7:23 37:6,9 38:20 39:1 55:7 60:2 73:18 75:6 77:15,20 84:10 98:22 106:1 145:6 153:25 155:20 165:1 183:21 184:15 188:21229:4 260:6 269:6,10 269:14 think 6:5,6,12 6:14 10:18 11:1 14:25 18:5 22:4 24:7 24:7 27:12 31:14 33:5,17 38:8 43:16 45:17 49:3 54:2,17 55:14 55:16 56:11 57:1160:2 63:8 65:3,11 65:12,16,18 68:3 69:22 71:2 72:12 74:4 75:16,20 75:25 76:24 78:16 83:25 84:21,22 86:24 87:2 89:25 90:10,1191:8 93:7,23 94:5 94:10,21,22 95:7 97:17 100:22,23 105:1,2,3,14 106:17 107:22 108:12 109:10 110:24 111:22 111:24 113:4 115:10,12 116:5,13 117:12 120:17 124:15,21 128:19 130:15 134:1 135:22 136:3,16 138:24 140:10 141:8,10 142:8 142:23 143:2 143:11,12 146:14 150:2 152:1,2 154:1 154:2 155:11 155:14 157:3 161:6,6 167:12 167:13,20 169:10,13,13 169:22 180:16 182:14 183:11 185:21 191:1 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 191:16 192:19 195:13 199:10 199:19 200:9 204:3,6 205:3 205:4,21 206:18 207:24 208:20 209:19 211:16 212:24 213:23,24 215:9 216:10 216:11219:4,6 219:9,13,24 220:10,15 225:7,20 226:10,12,13 226:25 227:15 229:22 231:19 234:15,15,16 235:19,21,23 239:23 242:11 244:20 245:19 246:11248:7 250:2 251:10 252:22 254:8,8 256:13 257:12 257:13 259:13 260:5,25 262:18,22 264:18 267:19 273:21 thinking 6:10 67:25 129:20 206:11 third 117:18 170:16 241:14 244:1 thorough 143:16 thought 36:1 46:16 60:3 74:24 97:3 140:9 150:9,17 159:20 160:8 185:13 203:19 203:20 204:13 207:6 208:14 210:20 216:10 220:9 239:9 261:4 264:19 thousand 33:18 53:22,24 54:1 54:3,4,15 151:20 187:9 187:16,20,21 187:24 190:7 190:22,24,24 252:23 253:20 266:18,18,21 thousands 190:14,17 204:10,14 206:14 209:10 254:2 Thrasher 217:3 217:9 threat 236:4,7 236:19 threaten 242:24 threatened 217:23 221:2 235:22 threatening 237:7 threats 222:8 235:15 236:10 three 33:18 41:14 103:6,13 122:14 147:19 153:22 155:17 200:6,12 203:19,20,23 203:24 205:25 206:3,17,18 221:10 three-year 156:10 thresh 229:7 threw 64:3 thrust 273:6 ticket 112:6 tied 13:14,17 tier 156:15 time 1:17 18:19 23:20 33:8 38:23 42:19 43:6,1150:9 51:159:1 63:10 69:6 75:9 76:2 84:3 84:21 100:1,12 107:23 117:3,4 119:18,21 121:17,18 132:7 134:25 135:5 138:24 141:10 146:14 155:7,18 156:1 160:1 169:8 176:17 179:20 185:12 199:23 205:11217:15 217:22 218:15 218:18 220:7 220:16 222:16 222:17 223:19 231:13 232:21 233:8 236:10 236:14 237:14 240:7 257:13 257:21261:7 261:16 265:7,9 266:17 277:10 277:17 278:3,7 279:4 timeline 32:23 times 3 3:1 41:14 55:2169:22 82:19 84:20 103:6 122:14 123:2 143:11 153:14,16,22 title 188:18 titled 76:16 Tobin 202:16,18 205:6 today 4:9 16:3,4 118:9 148:20 255:23 258:2 today's 174:24 told 35:22,25 36:6,11,19,21 36:22,25 37:7 38:11,1140:7 40:10 43:7 48:19 49:23 51:24 59:17 63:3 70:6 73:18 74:1 76:6 84:14 89:2197:21 102:6 121:10 130:2 133:8,15 140:9 146:17 152:21,23,25 157:3 161:10 163:11 171:18 196:4 205:21 209:9 221:20 222:20 232:25 236:2 248:3 258:25 259:14 260:4,7,9 263:23 264:3 264:25 265:1 269:21270:18 271:2,7 275:6 275:7 Tom 148:16 tonight 276:19 276:24 top 156:13,15 158:13,14,16 211:6 242:11 259:16 topic 97:3 108:16,19 112:25 topics 104:8 total 22:3,13 23:23 26:19,20 200:8,11 totally 160:19 209:15 towed 140:6,14 140:16,20 tower 266:15 towing 222:21 town 2:18 4:10 17:7,8 18:8 20:24 21:9 24:5,13,21,25 25:17 27:1,3 27:15,2128:24 30:2,4,6,7 56:1 57:8 60:19 61:3,6,7 62:18 65:13 100:15 127:11 129:11 138:18 139:6 140:6,16 142:13 149:18 149:18,19 154:12 160:6 173:9 177:18 179:5 186:7,7 186:12,13,19 187:7,8,13 188:9,12 189:23 190:9,9 191:10 192:1 192:20 193:17 200:4 203:12 205:10,16 206:24 207:20 211:2,14,20,21 212:1,15 214:12,14,15 214:16,22 215:1,5,13 216:17,23,25 217:2,6,9,23 221:2,8,22 222:10,11,15 222:17,18,23 225:25 226:3,5 226:7,21,23,25 227:7,8,11,18 228:1,9,23 229:3,9 235:11 235:11,12,16 235:24 240:23 242:13,14,21 243:4,16 244:12,16,16 244:22,24 245:25 246:4,6 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 37 246:7,14 248:3 249:11250:8 251:16,20,21 251:22 252:11 255:11257:2 257:14,25 258:1,2 265:4 265:20 266:13 Town's 17:9 25:2,10,13 67:1 160:23 222:19 227:13 234:21240:20 246:1254:20 townhouse 81:5 82:21 towns 137:17 track 214:4 trailer 198:3,4 198:13,17 199:7 201:1,21 trained 264:17 266:1 training 264:4 264:22 transcribed 31:15 284:12 transcript 31:14 31:17 33:21 52:2153:1 64:18,23 69:17 99:25 125:20 125:23 126:2 126:23 164:22 266:10 282:9,9 treated 116:6,8 117:16 130:20 130:22 tree 55:8 trespassing 199:11 trial 129:13,18 129:18,22 157:12 tried 55:5 114:9 172:19 265:15 triggered 89:12 triple 33:21 trouble 39:2 troubled 145:15 truck 140:2,3,5 140:6,10,12,15 140:15 211:21 211:22 212:4,6 222:16,21,24 true 40:17 44:4 143:8,10,12,13 143:21 149:4 149:13 163:7 179:12,13 185:18,19,20 185:20 186:16 191:2 193:19 203:20 204:8 205:23,23 206:1,18,20,20 207:7 215:17 227:23 269:11 282:9 Trump 155:20 Truss 21:14 truth 59:16 149:21 try 34:7 55:22 64:24 67:11 106:20 120:25 121:1 143:15 143:15 152:8 182:10 183:8 183:20 189:13 192:11 196:17 234:3,9 238:2 252:18 trying 6:7 8:1 38:6 42:19 55:1163:20 72:20 120:24 135:22 188:3 190:25 195:17 196:12,16 206:21 216:12 226:22 242:2 Tuesday 247:25 248:1 turmoil 247:8 turn 199:5,6 268:25 turning 242:11 twelve 211:14,17 214:9 253:15 twenty 54:15 151:5 202:13 235:9 twenty-five 54:1 54:3 257:2 twenty-nine 211:2 Twenty-one 241:18 245:24 Twenty-two 246:8 twice 156:12 168:4,5 two 20:25,25 42:9 93:1,17 122:14 147:19 153:18,22,23 156:10 157:21 169:23 173:3,4 183:20 186:21 186:21 200:6 200:12 205:3 221:12 225:15 226:1,13,14,15 264:6,8 266:5 271:11 two -minute 42:7 113:16 242:6 Tynin 87:9,10 87:12,20,24 88:24 89:6,16 90:6,14 91:15 92:16 93:2,16 94:7 102:2,4 103:24 104:5,9 type 19:4 46:3,4 59:8,9 73:16 75:14 81:4 157:25 158:10 158:12,12 238:13 241:6 267:14 types 49:9 142:15 251:1 typical 145:1 158:7 U ulterior 251:23 251:24 ultimate 244:9 244:11 ultimately 105:4 121:8 214:17 215:13 242:13 Um -hum 5:6 un 111:25 un -filed 60:20 un -ring 165:6 unacceptable 207:1 unauthorized 72:18 73:10 76:9,11,20 77:22 78:20 79:10 112:2 113:6 224:22 269:20 unaware 115:25 uncomfortable 100:15 underline 55:6 understand 4:21 8:1,6 9:6 25:7 26:5 34:2 37:12 48:5 84:5,5 94:18 99:4,11 145:5 167:2 183:5,14 183:17 189:11 192:11 196:16 204:3 212:24 219:23 229:23 230:2 248:24 252:22 256:23 understanding 17:14 23:16 25:8 28:15 31:5 44:25 56:15,25 84:4 99:6 115:11 118:12,15,16 118:16 172:25 182:24 254:22 254:23 understood 189:2 undertaken 227:6,12 unethical 37:15 56:5,13,13,19 unfortunately 238:4 252:17 253:23 254:6 266:23 unilaterally 166:14 UNITED 1:1 176:1 University 1:24 7:5,11 176:24 281:18 282:21 284:19 unlawful 75:11 85:2 unlicensed 65:24 67:1,22 69:12 69:20 73:15 83:15 88:8 89:1,8,2190:1 112:5 115:8 168:11 unlimited 34:17 unpleasantness 36:24 unprofessional 277:21 unpublished 108:22 unsealed 151:11 151:20 152:1,5 152:6,7 unusual 109:2,7 UPI, 65:4 72:11 73:4 102:3 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 M 105:13 upset 144:18,20 144:20 upstanding 30:9 urged 246:13 use 60:4 70:19 108:25 113:13 118:3 128:14 128:16 142:24 152:8 155:7 159:1 181:20 181:21 183:11 189:13,14 251:20 252:13 252:18 uses 169:14 usually 185:2 utilize 109:2 195:20 vacuum 228:20 250:13 various 60:19 189:24 191:10 193:17 203:13 203:18,23 205:17 206:16 206:17 214:10 214:13,21,25 235:13 vendors 244:2 venue 186:8 veracity 60:6 versus 4:10 14:14 62:19 vice 58:18 84:1 vicious 75:19,25 242:9 victims 49:17 video 126:23 165:10 videos 226:24 videotaped 31:15 125:20 125:23 126:2 view 196:5 209:9 234:24 252:16 viewed 251:24 vigilant 106:9 vigorously 235:19 violate 125:21 126:4,10 violated 227:10 227:18 273:14 violates 122:9 123:8 258:10 violation 88:22 88:25 165:2 192:13 195:13 196:7 211:19 212:13 213:7 violations 211:3 211:15 virtue 135:7,9 visibility 222:17 visit 36:23 Vitale 11:11,12 16:15 135:14 135:17 155:22 156:9 157:11 157:23 159:7 159:10,21 167:19 Vitale's 16:25 voice 227:12 241:21,23 242:4 voiced 226:8 volume 1:14 158:25 175:8 176:14 volumes 158:8 voluminous 50:6 volunteered 80:10 vote 254:24 255:1 voter 188:13 vs 1:6 176:6 179:5 260:24 261:2,3 263:12 284:7 wait 187:14 236:1,1,1 267:9 269:21 270:6 waiting 86:4 109:4 waive 100:7,10 180:7 280:2 waived 133:18 180:8 waiver 134:5 waiving 100:14 walk 220:4,4 233:4,5,6 walked 233:1 walking 72:13 72:23 want 7:2,16,18 10:4 17:23 20:18 24:19 25:20 29:17,19 33:5 35:19 39:4 41:3 44:8 44:25 47:2,3 48:10 49:12 52:6 53:6 62:14,14 66:7 66:11,22 67:8 67:9,17,19 68:12 70:21 71:4 72:1,21 76:5 80:11,13 89:22 98:13 99:7 100:9 101:11 106:13 106:17,21 107:4 110:20 112:9,10,10,13 112:25 124:7 125:9 129:11 132:2,19 136:7 137:13 141:23 144:14 154:19 167:1 170:6 173:15 180:1,2 180:3,22 181:7 181:25 182:3 182:17,19 183:2 184:23 185:9,10,12,15 185:18 194:4 194:13 201:9 201:11,13 206:22 207:5 207:22,24 216:13 218:16 218:17 220:4 220:12 224:8 224:10,10 230:14,14,16 230:21233:14 239:1242:5 243:10 262:13 263:22 271:11 271:13 277:9 277:13 278:18 279:5,8 wanted 31:23 33:18 34:20 37:13 38:17,18 88:3 91:1,12 144:25 182:23 201:14 221:22 237:23 239:6 266:15 wanting 225:13 Wanton 244:1 wants 52:10 184:22 279:6 wasn't 35:4 39:13 43:10 47:15 54:18 59:177:11 79:2 147:17 166:4 172:6 221:15 226:16 244:8,9 254:24 255:25 259:14 262:19 264:6 265:13 267:7,7 269:11 waste 100:1 231:13 wasteland 264:13 265:5 watch 132:10 watched 226:24 water 199:12 242:5 Watson 200:14 200:15 202:1,1 way 16:25 36:19 37:12 38:17,20 45:3,4,7,10 55:9,22 62:12 66:1172:13 75:11 82:9 84:17 99:9 100:21 102:22 108:15,24 112:23 118:2 131:23 132:15 137:8,25 147:2 159:25 184:12 193:11,22 194:5,10,11,14 195:3 205:6 212:8 214:17 215:16 230:2 231:21233:22 242:20 244:16 245:8 248:9 249:25 250:2 ways 126:20 we'll 6:15 9:9 18:14 42:10 44:18 58:7 69:6 83:23,24 92:10 113:2,2 113:15,17 169:2 172:25 181:20 201:16 209:8 230:4 243:1277:25 we're 18:7 42:8 65:25 69:19 72:4 84:13 113:17 127:10 129:13 166:21 167:12,13 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 39 171:15 175:6 181:8 182:4,15 182:21 187:4 219:6 220:2,3 220:10 225:20 233:8 242:11 249:4 255:23 256:24 263:8 276:25 277:5 we've 163:13,18 229:23 257:6 279:10 website 86:18 Wednesday 21:25 week 16:4 153:23 247:25 248:2 253:13 weekend 232:23 weekly 58:21 weeks 252:24 253:15 weigh 61:18 welcome 66:8 went 7:3 8:24 9:2 20:19 67:2179:15 105:7 117:14 138:24 193:15 208:20 232:6 239:20 240:13 266:3 268:19 274:16,23,24 weren't 24:9 35:17 75:19 West 2:3,13 177:3,13 284:5 whatever's 17:25 28:5 whatsoever 12:23 white 59:20 140:2,3,5 235:6 Whitmore 45:22 46:1,6 51:16 wide 273:23 wife 106:4 107:23 150:1,4 150:6,7 152:21 154:14 223:11 223:11,21,24 224:1,3,12,14 224:14 264:23 268:20,20 wife's 140:10,12 140:15 William 174:5,7 willing 15:4 17:19 99:12 Wills 21:14 windfall 36:7,16 266:11269:5 270:21274:14 wish 39:19 269:10,10,11 273:5 withdrawing 69:5 withdrew 264:9 264:14 witness 1:22 4:5 5:10,216:1 12:2 16:18 17:23 19:2,18 19:25 22:18 24:24 25:19 26:9,19 29:24 29:25 30:5,7 30:20,25 34:5 40:14 41:24 42:23 43:22 47:8 48:7,19 48:25 49:8 50:20 54:8,12 55:20 57:7 58:4,18 59:14 60:13 61:3,13 62:4,23 63:15 65:20 66:22,25 67:2168:14,19 69:7,16 70:22 71:20,22 72:20 73:12 76:23 77:13 78:1 79:12 80:5,14 80:22 81:17,22 82:4,8 83:5,20 85:5 87:22 88:11 89:11 91:7,19 92:8 93:4,18 94:15 95:4,12 96:1 96:13 97:17 98:20 99:9,19 100:19 101:15 101:24 102:15 105:17 106:11 107:4,11,18 108:6,18 109:6 109:16 111:11 111:19 112:9 112:15 113:6,9 113:12,16 115:25 116:21 117:21 118:12 118:21 119:4 120:3,10,21 121:7 122:11 123:19 124:4 124:24 125:9 125:23 126:13 127:1,16 128:2 129:12 130:5 130:14 132:2,7 132:11,16 134:12 135:22 137:1,10 138:13 139:11 139:23 140:19 141:13 142:1,8 143:21 145:9 145:17,21 146:10 148:9 149:10 152:12 153:21 154:8 154:19 155:5 158:20 160:13 160:18 161:6 162:13,20 163:1 164:14 165:8,20 166:17 167:5 169:5,22 170:11,23 174:6,19 175:2 175:3 176:22 179:19,25 180:22 181:1,5 181:21,24 182:1 183:25 184:6,9,21 185:1,24 187:18 192:7 192:11 193:1 195:24 199:9 201:9,13,17 202:3 203:16 204:20 205:20 206:6 208:5 209:2 212:23 213:2,15,22 218:10,15,22 219:8,11220:5 220:7,11 224:24 225:21 228:17 229:14 230:10,18 231:20 233:24 234:12 236:7 237:2,14 238:16 239:4 239:17 240:12 241:19 242:3 243:8 244:4 245:3,11,14,23 246:16,24 247:5,10 248:6 249:3 250:10 250:22 251:10 253:5 254:11 254:16 256:11 256:15,16 257:20 258:5 260:23 263:4 263:22 267:24 268:22 270:3,5 271:24 272:5 275:6 276:4,20 277:17 278:7 279:3,23 280:3 283:17 witnesses 18:3,4 60:1,18 138:5 143:15 238:2 woman 146:15 won 112:6 wonderful268:3 Wondering 255:4 word 5:4 38:14 60:8 64:24 84:4 88:18 102:8 153:13 165:16 169:16 169:18 205:5,7 224:1249:14 253:18 words 9:4 18:25 43:14 84:5,8 103:14 105:11 126:4 137:22 152:8 154:5,11 157:7 183:11 195:17 199:4 210:20 249:13 252:10 work 4:14,15 5:1 5:4,7,19,19 7:19 11:18 12:3 15:20,24 15:25 16:5,6 16:10,11,16,18 16:21 17:3,12 17:13 18:11 19:2122:12,14 25:24 26:2 29:22,24 30:12 31:8 33:2 43:20 44:5,6,9 48:16 60:17 93:22,23 95:16 96:7,14,15 97:4,12,12,25 101:19 104:23 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 105:11,14 112:10 128:1 134:14,20,21 134:22,25 135:3,6,7 137:1 143:16 147:10,11 152:18 157:25 158:8,10,18 159:23 162:5 168:18 173:17 191:24 194:3,4 194:6,12,13,16 194:17 197:3 204:21,24 209:17 222:22 226:19 240:20 245:15 247:12 247:14,21 249:6 250:5,15 252:11,12 267:10 worked 11:16,17 12:5,25 13:9 15:18 17:1 58:2195:13,17 95:17 96:2 134:9 156:1 157:11,16 224:16 working 17:16 33:15 35:8 156:11 167:24 works 15:2 16:8 world 31:7 98:10 155:21 165:12 worry 182:25 183:10 wouldn't 13:12 29:8 40:9 47:17 48:10 79:24 84:14 89:2 90:3 105:7,9,10,11 117:21,21 120:16 133:18 150:3 154:24 166:4,9 196:5 205:12 224:4 230:14 240:23 260:12 269:14 write 50:12 52:7 52:10 72:2 93:2,6,9 106:19 135:10 138:6 185:18 266:15 writing 91:10,13 92:18,19,25 102:7,16,21,22 103:23 104:14 138:19 writings 33:22 written 87:17 92:22,23 94:6 94:11 115:5 116:15,21 162:9,13 184:13 204:5 235:21 wrong 55:17 65:17 94:12 103:19 111:7 111:12 115:15 119:19 210:19 240:9 wrote 19:11 87:14,14,16 88:1 93:7,7 94:9 99:3 104:4 115:3 162:8 246:17 X Y yeah 8:13,24 17:6 26:9 39:9 57:16 72:25 79:24 85:9 89:7 95:24 113:8 115:2 126:6,15 138:16 164:24 165:14 167:22 181:17,19 182:25 185:1 185:17,22 187:18 201:11 204:8 216:9 219:22 220:9 220:10 229:4,6 234:14 241:21 244:22 254:22 256:5 261:22 262:8 year 11:21 84:3 157:13,14 159:3 211:12 211:16 225:22 years 5:22 9:14 9:19,20 18:22 19:3 20:25,25 54:25 74:15 93:1 127:22 151:5 152:25 153:24 154:15 189:22 190:7 191:9 193:14 202:13 203:11 205:15 223:9 224:6 225:12 226:1,13,15 254:4 yesterday 16:4 151:19 159:18 233:1 York 7:6 85:17 85:17 143:11 156:11 young 106:22 114:18,19 159:1201:6 225:8 238:17 267:10 268:24 269:11 youngest 218:17 11:15 3:12 22:15 174:21 179:8 233:15 282:9 1,000 46:15 1,700 273:18 1:11132:10 1:15131:23 1:30131:24 10210:1,19 10,000 216:12 273:17 10:48 42:18 1000 2:21 177:21 1001111:15 113:18 9:20 103:12 11/13/2012 111:5 119 210:5 227:22 244:2 11th 134:10,13 12 3:22 252:24 12:25108:15 122 3:22 125158:6,6,17 12802:3 177:3 13 216:14 219:6 219:7,9,12 13th 226:14 1411:22 136:6 217:13 219:9 219:10 220:9 220:10,15 15131:25 221:7 284:1 150157:9 158:6 158:17 15151:19 176:19 15th 151:21 193:21,25 213:5 226:15 281:13 282:16 16 225:16,19 1645 2:12 177:12 284:4 170,000 216:10 1700 266:21 174 3:12 1751:15 176176:15 179178:6 17th 200:16 180,000 214:19 216:5 181085 281:23 1891114:23 19 3:19,19,20 136:6 234:16 1961136:5 1980158:6 1986 9:14 2 94:1 101:10 178:15 245:23 245:25 260:14 260:15 267:23 280:7 20 236:1 241:12 200159:8,11 178:21 2000136:6 2013 214:12,24 201442:18 62:17 94:1 101:10 116:3 119:11,12 123:11 140:7 140:17 165:25 216:15,19 217:19 220:24 222:11,14 245:24,25 20161:16 176:16 281:11 281:13 282:16 283:23 284:1,7 2019 281:22 209178:22 21241:19 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 41 242:10 245:19 2146102:12 103:14 2241:24 176:24 281:18 282:22 284:19 2342:18 62:16 111:6 188:10 24 3:18 2455 2:21 177:21 2533:18 152:25 154:15 178:21 25 -year 153:5 25,000 255:11,20 256:23 250157:9 260178:15 2680114 211:19 271:16 176:16 284:7 275159:15 27th 281:11 28 3:20 283176:15 282:9 2nd 284:4 3116:3 119:11 119:12 181:13 3/20/2015 155:23 3:5642:19 30 9:14 3001:19 159:15 167:20 176:19 325 159:15 330711:25 176:25 281:19 282:22 284:20 333042:22 177:22 334012:13 177:13 284:5 334321:20 108:2 176:20 33442 2:4 177:4 33483188:11 350136:23 147:24 158:1 159:24 251:18 252:9 253:3 265:7 36 54:25 254:4 37 5:22 3rd 117:6,7 123:11,16 130:2,5,8 131:12 163:16 163:19 164:1,2 243:9,13 4 3:5 281:22 4-5.5127:13 4-8.3127:13 4:00 183:4 4:30 171:20 182:5,23 183:3 183:8 232:14 44 3:21 57:13 4474 57:5 63:12 63:25 45,000159:3 47 52:16 5242:12 5:00 218:9 221:11231:19 50 52:16 159:4 500 217:25 221:5 56177:23 78:12 57105 258:6 6 6/19/2015 211:6 6:00 231:19 6:36 273:11 6:40 279:12,13 6:41278:5 6:44 280:11 60,000 253:12 600,000159:18 62 225:13,17 64 225:17 650158:2,13,17 159:23 167:19 6800107:25 6th 108:1 7 7186:10 7:001:17 176:17 219:25 279:11 70179:11 185:11 83:21 186:20 8,200 263:7 8,260 261:10 8:00 232:9,11,14 232:17 817163:9 272:11 9 9178:22 207:7 9:001:17 176:17 219:25 279:10 9:14 -CV -8125... 1:3 176:3 9:25 278:5 9341:24 176:24 281:18 282:21 284:19 Daughters Reporting, Inc. Fort Lauderdale, Florida 954-755-6401 3