---
type: court_doc
id: "court_ctb_2292_39"
court: "CTB"
case_no: "22-50073"
doc_number: 2292
doc_type: "EXHIBIT"
filed_date: "2023-10-26"
lang: "zh"
url: "https://mubeitech.com/court/court_ctb_2292_39"
json_url: "https://mubeitech.com/api/court/court_ctb_2292_39"
---
# Exhibit 39 UNITED STATES BANKRUPTCY COURT
> 原始法庭文件为英文；下方为英文全文，顶部为中文摘要。
## **Exhibit 39**
Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 2 of
46
UNITED STATES BANKRUPTCY COURT
DISTRICT OF CONNECTICUT
BRIDGEPOINT DIVISION
---------------------------------------------------X
Debtors, CHAPTER 11 CASE: 22-50073 (JAM) ---------------------------------------------------X LUC A. DESPINS, CHAPTER 11 TRUSTEE, Plaintiff, -against-GREENWICH LAND, LLC and HING CHI NGOK, Adv Proceeding 23-05005 Defendants. ---------------------------------------------------X VIDEOTAPED DEPOSITION OF EMILE DE NEREE
NEW YORK, NEW YORK
August 24, 2023
REPORTED BY: KIARA MILLER
FILE NO.: 7808
HO WON KWOK, et al.,
Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 3 of
| | 46 | | |
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| | Page 2 | | Page 3 |
| 1 | UNITED STATES BANKRUPTCY COURT | 1 | A P P E A R A N C E S: |
| 2 | DISTRICT OF CONNECTICUT | 2 | |
| 3 | BRIDGEPOINT DIVISION | 3 | ON BEHALF OF LUC A. DESPINS, CHAPTER 11 TRUSTEE: |
| 4 | ---------------------------------------------------X | 4 | PAUL HASTINGS |
| 5 | HO WON KWOK, et al., | | 200 Park Avenue |
| | | 5 | New York, NY 10166 |
| 6 | Debtors, CHAPTER 11 | 6 | EMAIL: nicholasbassett@paulhastings.com |
| 7 | CASE.: 22-50073 (JAM) | 7 | BY: NICHOLAS BASSETT, ESQ. |
| 8 | --------------------------------------------------X | 8
9 | ON BEHALF OF DEFENDANTS: |
| 9 | LUC A. DESPINS, CHAPTER 11 TRUSTEE, | 10 | MEISTER, SEELIG & FEIN, PLLC |
| 10 | Plaintiff, | | 125 Park Avenue, 7th Floor |
| 11 | -against | 11 | New York, NY 10017 |
| 12 | GREENWICH LAND, LLC and | 12 | EMAIL: CJM@MSF-LAW.COM |
| 13 | HING CHI NGOK, | | ADK@MSF-LAW.COM |
| 14 | Defendants. | 13 | |
| 15 | ---------------------------------------------------X | | BY: CHRISTOPHER J. MAJOR, ESQ. |
| 16 | | 14 | AUSTIN KIM, ESQ. |
| 17 | Deposition of EMILE DE NEREE, taken on behalf | 15 | |
| 18 | of DEFENDANTS, at Remote Location, New York, | 16
17 | |
| 19 | New York, commencing at 10:09 a.m., August 24, | 18 | ALSO PRESENT: |
| 20 | 2023, before Kiara Miller. | 19 | VIDEOGRAPHER, DEANE CARSTENSEN |
| 21 | | 20 | |
| 22 | | 21 | |
| 23 | | 22 | |
| 24 | | 23 | |
| 25 | | 24 | |
| | | 25 | |
| | | | |
| | | | |
| | Page 4 | | Page 5 |
| 1 | VIDEOGRAPHER: We are now on | 1 | plaintiff in this adversary |
| 2 | the record. Today's date is | 2 | proceeding. I am joined by my |
| 3 | August 24, 2023. The time right now | 3 | colleague Luyi Song, also from Paul |
| 4 | is 10:09 a.m. Eastern time. This is | 4 | Hastings. |
| 5 | the video deposition of Emile de | 5 | MR. MAJOR: Good morning. |
| 6 | Neree. In the matter of Luc A. | 6 | Chris Major, Meister, Seelig & Fein. |
| 7 | Despins, Chapter 11 Trustee versus | 7 | We represent Hing Chi Ngok and |
| 8 | Greenwich Land, LLC, and Hing Chi | 8 | Greenwich Land, LLC., the defendants |
| 9 | Ngok, filed in the United States | 9 | in this adversary proceeding. And |
| 10 | Bankruptcy Court, District of | 10 | I'm joined by Austin Kim my partner |
| 11 | Connecticut, Bridgepoint Division. | 11 | at Meister, Seelig & Fein. |
| 12 | This deposition is taking place via | 12 | VIDEOGRAPHER: Our court |
| 13 | web via conference with all | 13 | reporter today is Kiara Miller also |
| 14 | participants attending remotely. | 14 | representing TransPerfect. The |
| 15 | My name is Deane Carstensen. | 15 | court reporter can now swear in the |
| 16 | I'm the videographer representing | 16 | witness and then we may proceed. |
| 17 | TransPerfect today. Will counsel on | 17 | EMILE DE NEREE, after having first been duly sworn |
| 18 | the conference please identify | 18 | by a Notary Public of the State of New York, was |
| 19 | yourselves and state whom you | 19 | examined and testified as follows: |
| 20 | | 20 | COURT REPORTER: Please state |
| 21 | represent, beginning with the | 21 | your name and address for the |
| | questioning attorney. | 22 | |
| 22 | MR. BASSETT: Good morning, | | record. |
| 23 | everyone. Nick Bassett from Paul | 23 | THE WITNESS: Emile de Neree, |
| 24
25 | Hastings on behalf of the Chapter 11
Trustee, Luc Despins, who is the | 24
25 | D-E, N-E-R-E-E. I'm a realtor with
Compass in Greenwich, Connecticut. |
2 (Pages 2 to 5)
Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 4 of
| | 46 | | |
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| | Page 6 | | Page 7 |
| 1 | 200 Greenwich Avenue, Greenwich, | 1 | question that I ask that you don't |
| 2 | Connecticut. | 2 | understand, please let me know. I'm happy |
| 3 | EXAMINATION BY | 3 | to try to rephrase or clarify, to the best |
| 4 | MR. BASSETT: | 4 | that I can. |
| 5 | Q
Again, by way of introduction, | 5 | I'm not sure how long we'll go |
| 6 | Mr. de Neree, I'm Nick Bassett. As I said, | 6 | today, but if at any time you need a break |
| 7 | I represent Luc Despins as the Chapter 11 | 7 | for any reason, don't hesitate to let us |
| 8 | Trustee who's the plaintiff in this | 8 | know. We want to make sure you're |
| 9 | litigation. Thanks again for your time and | 9 | comfortable and have any breaks that you |
| 10 | for being here today. We all appreciate it. | 10 | need. The only thing we will both ask is |
| 11 | Mr. de Neree, have you had the | 11 | that if we have a question that's pending to |
| 12 | pleasure of sitting for a deposition before, | 12 | you, that we would just get an answer to |
| 13 | or is this your first time? | 13 | that question before we take a break. |
| 14 | A
First time. | 14 | There may be some objections by |
| 15 | Q
Okay. In that case, I'll just | 15 | counsel after questions today. Generally |
| 16 | spend a couple of minutes kind of giving you | 16 | speaking you can just let the objection be |
| 17 | the lay of the land in terms of how today's | 17 | made and then you would still answer the |
| 18 | going to proceed. | 18 | question after that. You'll kind of see how |
| 19 | To state the obvious, I will ask | 19 | that goes as we get going. |
| 20 | you a series of questions. Mr. Major, who's | 20 | Just for the record, are you alone |
| 21 | also here on behalf of the defendants, may | 21 | in that room today, Mr. de Neree? |
| 22 | have questions when I'm done. As you know, | 22 | A
Yes, I am. |
| 23 | based on what just occurred, you're under | 23 | Q
Do you have access to any email or |
| 24 | oath. So we both ask that you answer our | 24 | text or anything like that while we're on |
| 25 | questions truthfully. If there is a | 25 | the deposition? |
| | | | |
| | | | |
| | Page 8 | | Page 9 |
| | | | |
| 1 | A
Email going back to the issue at | 1 | Banker at that time and left Coldwell Banker |
| 2 | hand? | 2 | about a year and a half ago to go to |
| 3 | Q
No. I just meant like on your | 3 | Compass. |
| 4 | screen, your computer screen for example | 4 | Q
When have you say at that time |
| 5 | your Outlook up, I would close that out just | 5
6 | what do you mean? |
| 6
7 | so there's no issue about whether you're | 7 | A
Meaning from the beginning when I |
| 8 | receiving communication during the | 8 | had my real estate license until a year and |
| 9 | deposition, that's all?
A
No, no it's not up. | 9 | a half ago.
Q
Got it, understood. And as a real |
| 10 | Q
Okay, got it. So, Mr. de Neree, | 10 | estate salesperson, do you represent both |
| 11 | you are a licensed real estate broker; is | 11 | buyers and sellers? |
| 12 | that correct? | 12 | A
Yes. |
| 13 | A
Yes. Salesperson. | 13 | Q
And if you can just describe for |
| 14 | Q
Salesperson, okay. Do you | 14 | me if you're representing a buyer who's |
| 15 | primarily focus on selling homes in | 15 | looking to purchase a home. Can you just |
| 16 | Connecticut or is your footprint broader | 16 | kind of just tell me what are the services |
| 17 | than that? | 17 | that you provide for them? |
| 18 | A
No. Connecticut. | 18 | A
Well, I basically search out a |
| 19 | Q
How long have you been a real | 19 | property that is appropriate for them in |
| 20 | estate salesperson? | 20 | terms of their budget and preferences. |
| 21 | A
Roughly since 2011, I believe '11 | 21 | Q
So the perspective buyer would |
| 22 | or '12. It was '11. | 22 | tell you what type of property they're |
| 23 | Q
Okay. Got it, and you work for | 23 | looking for and then give you some direction |
| 24 | Compass; is that right? | 24 | as to what to go find for them, you would go |
| 25 | A
I do now. I worked for Coldwell | 25 | out and do that and report back what you |
3 (Pages 6 to 9)
| | 46 | | |
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| | Page 10 | | Page 11 |
| 1 | found. Is that generally how it works? | 1 | this. This looks like an assortment of |
| 2 | A
Yes. | 2 | sales that I've had over the years. |
| 3 | Q
And I assume typically before a | 3 | Q
That's obviously you and your |
| 4 | buyer decides to make an offer on the home | 4 | picture there on the first page? |
| 5 | they may visit the property? | 5 | A
Yes. |
| 6 | A
Yes. | 6 | Q
And if you look it says that |
| 7 | Q
Okay. I'll ask my colleague to | 7 | you're a water front and luxury property |
| 8 | put tab one on the screen or into the chat | 8 | specialist, is that an accurate description |
| 9 | if she could. And, Mr. de Neree, just let | 9 | of how you would describe your real estate |
| 10 | me know once you have that open. | 10 | practice? |
| 11 | A
Social media, transactions, yes | 11 | A
Yes. |
| 12 | sales. | 12 | Q
I guess, what does that mean to |
| 13 | Q
So you have the document up? | 13 | you? |
| 14 | A
Yep. | 14 | A
Well, luxury is obvious. It's not |
| 15 | Q
I'd ask the court reporter please | 15 | low priced homes. And water front is |
| 16 | mark this document as de Neree Exhibit 1. | 16 | because of my background. I'm a sailor and |
| 17 | (Whereupon, Emile de Neree's | 17 | I live on the water myself, I live in a |
| 18 | Compass Transactions was marked | 18 | community of 100 homes all of which are on |
| 19 | as Exhibit 1 for identification | 19 | the water. So I've had a lot of local |
| 20 | as of this date.) | 20 | transactions within the community and also |
| 21 | Q
I believe, Mr. de Neree, this is a | 21 | all over Greenwich and I tend to focus on |
| 22 | profile of yours that we obtained from the | 22 | water front because of my expertise. |
| 23 | Compass website; does this look familiar to | 23 | Q
Understood. And then below it |
| 24 | you? | 24 | says past sales and it lists a bunch of |
| 25 | A
No. I've never actually seen | 25 | properties. Are these properties that |
| | | | |
| | Page 12 | | Page 13 |
| | | | |
| 1 | you've sold, bought, both, just trying to | 1 | A
Yeah. I only know him by Miles. |
| 2 | understand what that means? | 2 | Q
But if I say Ho Won Kwok, you'll |
| 3 | A
It is a combination of both. Not | 3
4 | understand now Miles to be Ho Won Kwok, who |
| 4
5 | just where I was on the sale side, but I | 5 | is the Chapter 11 debtor in this case, |
| 6 | believe it was some definitely here on the | 6 | correct?
A
Yeah. I understand. And also |
| 7 | buy side, it's a combination of both, yes.
Q
The second property is 323 Taconic | 7 | from social media that he went by several |
| 8 | Road in Greenwich, which is a property that | 8 | names. I was only aware of one, Miles. |
| 9 | we'll be talking more about today. I'll | 9 | Q
Understood. I'll go ahead and |
| 10 | just ask you, did that property actually | 10 | refer to him as Miles today, then. |
| 11 | sell for the \$7.495 million? | 11 | Did you at some point develop a |
| 12 | A
No. It did not. | 12 | professional relationship with Miles? |
| 13 | Q
Are some of these list prices | 13 | A
Yes. |
| 14 | instead of -- | 14 | MR. MAJOR: Objection to form. |
| 15 | A
Those are probably original list | 15 | Q
Can you describe that relationship |
| 16 | prices. | 16 | to me? |
| 17 | Q
Understood, okay. | 17 | A
I'm sorry. |
| 18 | A
Not even necessarily the list | 18 | Q
Would you please describe that |
| 19 | price at the time of the transaction. | 19 | relationship? |
| 20 | Q
Got it, got it. So are you, | 20 | A
Was that an objection? |
| 21 | turning to the matter at hand, if you will, | 21 | Q
Yes. Mr. Major said objection to |
| 22 | are you familiar with, Mr. de Neree, with a | 22 | form, which is an objection you may hear |
| 23 | person named Ho Won Kwok who is the debtor | 23 | more than once today. And as I said before, |
| 24
25 | in this Chapter 11 case who has otherwise
gone by Miles Kwok or Miles Guo? | 24
25 | that's something that the lawyers will deal
with later. For your purposes, you just |
# 4 (Pages 10 to 13)
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| 1 | answer the question. | 1 | actually not with Miles, but Max first, was |
| 2 | A
I see. Understood. What was your | 2 | around October of 2018 and the ultimate |
| 3 | question again quickly? | 3 | transaction of this property we're talking |
| 4 | Q
The question was just whether you | 4 | about didn't take place until February |
| 5 | could please describe for me the nature of | 5 | of 2000. |
| 6 | that relationship with Miles? | 6 | Q
Understood. And do you have some |
| 7 | MR. MAJOR: Objection to form. | 7 | documents there with you Mr. de Neree? |
| 8 | A
I showed him several properties | 8 | A
I do have some, yeah. |
| 9 | over about a one and a half year period. | 9 | Q
Can you just let me know the |
| 10 | And he would tell me what he liked, what he | 10 | document that you were just looking at. Is |
| 11 | didn't like, then there would be followup | 11 | that -- |
| 12 | from his assistant, Max Krasner, about | 12 | A
Well, one document -- just for |
| 13 | details if he wanted to see more, what he | 13 | clarification, I do not have any emails |
| 14 | liked a lot, what he didn't like as much. | 14 | because my email account was taken away from |
| 15 | He would sort of give me more feedback, if | 15 | me. Except for the important documents that |
| 16 | you will. And then I would set up other | 16 | I would have made hard copy of from my file |
| 17 | showings as they came available, in other | 17 | because I was doing that at the time, I |
| 18 | words as properties were listed and I | 18 | don't have every email. I have, I was able |
| 19 | thought he would be interested in them, I | 19 | to reconstruct some of my texts, but I don't |
| 20 | would show those properties. | 20 | have emails and really all I have is some |
| 21 | Q
Thank you. So you said that this | 21 | key documents, like offer to purchase, |
| 22 | was over, I believe approximately one year | 22 | exclusive right to represent the buyer and |
| 23 | period or was it longer than that? | 23 | accepted offer on this property and |
| 24 | A
It was a bit longer than that. I | 24 | ultimately the contract to purchase real |
| 25 | believe my first communication with Max, | 25 | estate, which is the closing document. I |
| | Page 16 | | Page 17 |
| 1 | have some documents regarding the inspection | 1 | said I have a client who's interested in |
| 2 | of the property during the week that this | 2 | looking at some properties, I understand you |
| 3 | took place and that's about it. And I have | 3 | have water front experience. He likes the |
| 4 | a nondisclosure confidentiality agreement | 4 | idea of water front, he has a big boat, he |
| 5 | that I signed around that date and that | 5 | would like to live on the water in |
| 6 | would have been one of the first sort of | 6 | Greenwich. What can you show us. And I |
| 7 | actions, that's why I refer to October 22, | 7 | went through a bunch of things and I said I |
| 8 | 2018. | 8 | could show this, this and this, but there |
| 9 | Q
Understood, okay. So I'm going to | 9 | |
| 10 | | | wasn't much water front available at that |
| 11 | show you some documents today, some | 10 | time so we ended up looking at other |
| | additional documents today. And I think | 11 | properties also. So that's how the |
| 12 | once I've done that and finished that I may | 12 | relationship got started. |
| 13 | ask you if there are any other documents you | 13 | Q
So Mr. Krasner said he -- that |
| 14 | have there that we have not shown, I think | 14 | Miles was wanting to find a home for himself |
| 15 | we'll proceed that way. And then we may ask | 15 | in Connecticut, in Greenwich? |
| 16 | that those documents to be provided to us if | 16 | MR. MAJOR: Objection to form. |
| 17 | they have not been already. | 17 | A
Correct that's what he said, yes. |
| 18 | A
Okay. | 18 | Q
Okay. So you understood that |
| 19 | Q
So you said the relationship began | 19 | whatever property you might find it would be |
| 20 | around roughly October 2018, that's your | 20 | one for Miles? |
| 21 | recollection? | 21 | MR. MAJOR: Objection to form. |
| 22 | A
Yes. | 22 | A
Correct. |
| 23 | Q
How did you first come in contact | 23 | Q
I'd like my colleague to show |
| 24 | with the Miles? | 24 | Tab 2, please? |
| 25 | A
Max called me, asked for me and | 25 | A
Yeah, that's the one I was |
5 (Pages 14 to 17)
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| 1 | referring to, it's called Exclusive Right to | 1 | Q
And the buyer in the first line is |
| 2 | Represent Buyer Agreement. | 2 | listed as Hudson Diamond. Do you have any |
| 3 | Q
Thank you. | 3 | understanding of who or what Hudson Diamond |
| 4 | MR. BASSETT: Just give me a | 4 | is? |
| 5 | moment. I'd like the court reporter | 5 | A
No. I was told by Max that this |
| 6 | to please mark this document as de | 6 | is one of the companies that they owned, |
| 7 | Neree Exhibit 2. | 7 | that's all. |
| 8 | (Whereupon, Exclusive Right to | 8 | Q
When you say they owned, what do |
| 9 | Represent Buyer Agreement | 9 | you mean? |
| 10 | (GREE002323) was marked as | 10 | A
Miles, that Miles owned. |
| 11 | Exhibit 2 for identification as | 11 | Q
Okay. |
| 12 | of this date.) | 12 | A
Yes, that's what I was told at the |
| 13 | Q
And just for the record, this | 13 | time, I'm just looking at the signature line |
| 14 | document is Bates labeled at the bottom of | 14 | cause I can't remember, it basically says |
| 15 | the first page GREE002323. | 15 | Hudson Diamond and an unrecognizable name. |
| 16 | A
Yeah. | 16 | You know, there was an addendum to this. I |
| 17 | Q
So this is the exclusive right to | 17 | don't know if you have that. |
| 18 | represent buyer agreement. Is this a | 18 | Q
When you say addendum, is that in |
| 19 | standard agreement that you would execute | 19 | paragraph two where it says, "See Exhibit A |
| 20 | with a perspective buyer of property who is | 20 | attached hereto"? |
| 21 | retaining you for your services? | 21 | A
Yeah. |
| 22 | A
Yes. | 22 | Q
We do not have that, to my |
| 23 | Q
And the agreement is dated | 23 | knowledge. If you happen to have that, |
| 24 | January 13, 2019. Do you see that? | 24 | that's another document. |
| 25 | A
Yeah. | 25 | A
The reason why is this. Because |
| | | | |
| | | | |
| | Page 20 | | Page 21 |
| 1 | they crossed out a whole section about | 1 | owned by Miles, correct? |
| 2 | compensation, the whole thing. And it | 2 | A
Correct. |
| 3 | became rather narrow. And they said, we | 3 | Q
I think you also had testified |
| 4 | will only compensate you for properties that | 4 | that Mr. Krasner had reached out to you in |
| 5 | you have shown Miles. | 5 | order to find a property for Miles. |
| 6 | So I submitted a list of five | 6 | So my question is, I guess, how do |
| 7 | properties or four or five properties. And | 7 | you sort of -- is it your understanding that |
| 8 | subsequently asked to have a few more added, | 8 | Miles was going to use Hudson Diamond to |
| 9 | which I had also shown him, but they never | 9 | acquire the property for him? Is that the |
| 10 | added it to the exhibit. But the properties | 10 | relationship between the two? I'm just |
| 11 | were 125 Pecksland Road, which was the first | 11 | trying to understand. |
| 12 | one I showed him. 586 Roundhill Road. 373 | 12 | MR. MAJOR: Objection to form. |
| 13 | Taconic, which is the subject property. | 13
14 | A
No. I had no assumption like that |
| 14 | Private island on Connecticut Gold Coast. | 15 | because I was under the impression that he |
| 15
16 | Wallacks Point was the actual address. And | 16 | owned many different companies, and I had no |
| 17 | any additional properties in Connecticut
that Coldwell Banker presents to buyer and | 17 | idea in which way he was going to purchase
the property at the time. |
| 18 | buyer agrees to view. | 18 | Q
Understood. |
| 19 | So he added this for my | 19 | A
I was just representing Miles. |
| 20 | protection, call it, so that I would be | 20 | And I hoped that this Hudson Diamond was a |
| 21 | covered under this agreement. | 21 | legitimate company. I did not research it |
| 22 | Q
Okay. Understood. | 22 | or anything like that. I was, at the time, |
| 23 | And back to Hudson Diamond. So I | 23 | just hoping that he would have an interest |
| 24 | think what you just testified was that you | 24 | in one of those properties and proceed. |
| 25 | were told by Mr. Krasner, that was an entity | 25 | Q
As a real estate salesperson, in |
6 (Pages 18 to 21)
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| | Page 22 | | Page 23 |
| 1 | your experience, have you seen scenarios | 1 | Q
I was going to ask you if you had |
| 2 | where an individual will use a company or an | 2 | any understanding of what that signifies? |
| 3 | LLC to acquire a property? | 3 | MR. MAJOR: Objection to form. |
| 4 | A
Yes. Many times. | 4 | A
I mean, I knew Miles by his first |
| 5 | MR. MAJOR: Objection to form. | 5 | name, so I did not notice it before. But, |
| 6 | Q
Is that what happened here? | 6 | yeah, that would have meant for me that this |
| 7 | MR. MAJOR: Objection to form. | 7 | was, in fact, for Miles. |
| 8 | A
Yes. It happened here. | 8 | Q
Understood. Back to the |
| 9 | Q
So you spoke a little bit about | 9 | compensation provision that you mentioned, I |
| 10 | the compensation -- I guess, actually before | 10 | was going to ask you why that was crossed |
| 11 | I go to that. At the bottom, if you look at | 11 | out. So thanks for that explanation. |
| 12 | the bottom right-hand corner of each page of | 12 | As to the properties that you did |
| 13 | this agreement, it says, underneath buyer's | 13 | show, how was it agreed that you would be |
| 14 | initials, in all caps, Miles Guo. | 14 | compensated? |
| 15 | Do you see that? | 15 | A
There is no promise of |
| 16 | It's small. You may have to zoom | 16 | compensation for any showings I do, |
| 17 | in. | 17 | regardless of how man, short of a sale. I |
| 18 | A
I'm sorry, where do you say you | 18 | can only be compensated in the case of a |
| 19 | see this? | 19 | sale. |
| 20 | Q
The bottom right-hand corner of | 20 | Q
Okay. And in the case of a sale, |
| 21 | every page of this. If you -- | 21 | you would, of course, receive a commission; |
| 22 | A
Yeah. I see it now. I never saw | 22 | is that right? |
| 23 | it before. Let me make sure it's on the | 23 | A
Correct. |
| 24 | original. Yes. It is on the original. I | 24 | Q
Understood. If you look at the |
| 25 | never saw that before. Yes. | 25 | part where it says buyer's obligations, |
| | | | |
| | Page 24 | | Page 25 |
| | | | |
| 1 | that's paragraph six. I wanted to ask you a | 1 | Q
My question for you is: Did you |
| 2 | couple of questions about that. | 2 | ever receive, in connection with this |
| 3 | A
Yeah. Paragraph six you said? | 3 | engagement, any of the information |
| 4 | Q
That's correct. And I think, | 4 | referenced here concerning buyer's needs and |
| 5 | Mr. de Neree, as difficult as it might be, I | 5 | qualifications, including personal, |
| 6
7 | think for the record, if you can just try to | 6
7 | financial and confidential information? |
| 8 | use the one on your screen, zooming in if | 8 | A
Not really. No. I mean, it |
| 9 | possible, that way there's no -- I don't
want there to be any ambiguity about whether | 9 | was -- very few details were given to me.
Other than what he liked, what he didn't |
| 10 | we're looking at the exact same document. | 10 | like, maybe why he didn't like it and that |
| 11 | A
No. We're looking at the exact | 11 | was it. |
| 12 | same document. And this is standard, call | 12 | Q
So you didn't receive any |
| 13 | it Coldwell Banker standard document. | 13 | information regarding Miles' financial -- |
| 14 | Q
Understood. And I just want to | 14 | A
No. |
| 15 | ask you a couple of quick questions about | 15 | Q
-- situation? |
| 16 | it. | 16 | A
No. Never. |
| 17 | So the first line in that says, | 17 | Q
The next line talks about buyer |
| 18 | well, it says, "Buyer's obligations: A, | 18 | being obligated to pay for out-of-pocket |
| 19 | buyer will cooperate with Coldwell Banker; | 19 | expenses. |
| 20 | one, by providing all information necessary | 20 | Do you see that? |
| 21 | to evaluate buyer's needs and | 21 | A
Correct. |
| 22 | qualifications, including personal, | 22 | Q
Were there any out-of-pocket |
| 23 | financial and confidential information." | 23 | expenses that you incurred in the engagement |
| 24
25 | Do you see that?
A
Yes. | 24
25 | that the buyer paid for?
A
No. He paid directly for the |
7 (Pages 22 to 25)
| 46 | | | | |
|--------|--------------------------------------------------------------------------------------|--------|----------------------------------------------------------|--|
| | Page 26 | | Page 27 | |
| 1 | inspection. And I believe those were the | 1 | A
Yes. | |
| 2 | only out-of-pocket expenses incurred. And | 2 | Q
Did you ever communicate with | |
| 3 | so, no, I did not. | 3 | Miles himself? | |
| 4 | Q
Okay. Did this agreement ever | 4 | A
No. Not via email or text. I | |
| 5 | terminate at any time? Did it terminate | 5 | didn't have his phone number, nor an email | |
| 6 | upon a transaction, is it still open? | 6 | address. So, no, all communication was with | |
| 7 | A
On this particular document, there | 7 | Max, with the exception of communication I | |
| 8 | was no term limit. Which, again, you know, | 8 | had with him at the properties. | |
| 9 | probably I could have nailed them, but at | 9 | Q
So you met Miles in person when | |
| 10 | the time, that wasn't my concern. I was | 10 | showing properties? | |
| 11 | just hoping to find something that they | 11 | A
Yes. | |
| 12 | would like and would be interested in | 12 | Q
We'll get to that in a little bit | |
| 13 | buying. | 13 | more detail in a moment. | |
| 14 | So, no, there's no limit to this. | 14 | I'd like my colleague to put up | |
| 15 | It says term here. It's not filled in. | 15 | tab three. | |
| 16 | Q
Okay. And did you ever enter into | 16 | A
Yes. Got it. | |
| 17 | any other agreement like this one with | 17 | Q
Thank you. | |
| 18 | another entity related to Miles? | 18 | (Whereupon, Text Messages was | |
| 19 | MR. KIM: Object to the form. | 19 | marked as Exhibit 3 for | |
| 20 | A
No. I did not. | 20 | identification as of this date.) | |
| 21 | Q
I believe you said you were | 21 | MR. BASSETT: I'd like the | |
| 22 | originally approached by Mr. Krasner about | 22 | court reporter to please mark this | |
| 23 | this engagement. Was Mr. Krasner the person | 23 | as de Neree Exhibit 3, please. | |
| 24 | you most often communicated with concerning | 24 | Q
Mr. de Neree, I understand the | |
| 25 | this engagement? | 25 | document that has just been marked as | |
| | | | | |
| | | | | |
| | Page 28 | | Page 29 | |
| | | | | |
| 1 | Exhibit 3 shows your text images. | 1 | some that are kind of aligned more in the | |
| 2 | Is that your understanding? | 2 | middle. Do you know what it is -- | |
| 3 | MR. MAJOR: Objection to form. | 3 | A
Yeah. So what's on the left is | |
| 4 | A
Yes. | 4 | Max, and what is on the right is me. | |
| 5 | Q
And where did you obtain -- is | 5 | Q
Okay. So on the left-hand page, | |
| 6 | this a document that you, to your | 6 | these are messages sent to you by | |
| 7
8 | recollection, had produced to the Trustee in | 7
8 | Mr. Krasner? | |
| 9 | response to our subpoena in this case? | 9 | A
Correct. | |
| 10 | A
Yes. | 10 | Q
And the ones that are oriented | |
| 11 | Q
And where did you get this | 11 | toward the middle, those are your messages | |
| 12 | document? | 12 | to Mr. Krasner? | |
| 13 | A
From my phone. Actually, I'm not | 13 | A
Correct.
Q
Is that true for this entire | |
| 14 | sure it was the phone. It could have been | 14 | | |
| 15 | the computer. But in either case, it's text | 15 | document? If you go through all of them, I | |
| 16 | messages that came in, because my Mac also | 16 | don't know how many pages there are here. | |
| 17 | shows text messages. I can't remember
whether it was printed from the computer or | 17 | A
Yes. Yes, it is.
Q
This consists only of text | |
| 18 | from the phone. | 18 | messages between you and Mr. Krasner, with | |
| 19 | Q
At the top, it says, iMessage. So | 19 | Mr. Krasner on the left, and yours more to | |
| 20 | to be more accurate, would this be iMessages | 20 | the middle? | |
| 21 | using an Apple device? | 21 | A
Yes. | |
| 22 | A
Correct. | 22 | MR. MAJOR: Object to the | |
| 23 | Q
Can you just try to orient me. It | 23 | form. | |
| 24 | looks like there are some messages that are | 24 | Mr. de Neree, if I could ask | |
| 25 | aligned on the left-hand side of page and | 25 | you to please allow some time for me | |
8 (Pages 26 to 29)
| | of 46 | | | |
|----------|-------------------------------------------------------------------------------------------|----------|--------------------------------------------------------------------|--|
| | Page 30 | | Page 31 | |
| 1 | to the object before you answer | 1 | aware of any other text messages you had | |
| 2 | questions. I know this is an | 2 | with Mr. Krasner that are not shown here? | |
| 3 | unnatural setting. And in | 3 | A
No. | |
| 4 | conversation it's often custom to | 4 | Q
And that's true before, you don't | |
| 5 | respond to someone before they | 5 | recall having any text with him before | |
| 6 | finish their question. But if you | 6 | November 5, 2018? | |
| 7 | could please let Mr. Bassett finish | 7 | A
Correct. | |
| 8 | his question and pause for just a | 8 | Q
And then just to be clear, no text | |
| 9 | moment, in case I have an objection | 9 | after August 23, 2022? | |
| 10 | to put in for the court reporter. | 10 | A
Correct. | |
| 11 | Thank you. | 11 | Q
And, again, just so we're totally | |
| 12 | THE WITNESS: Absolutely. | 12 | clear, and to best of your knowledge, | |
| 13 | Thank you. | 13 | between November 5, 2018 and | |
| 14 | Q
Mr. de Neree, at the very top, it | 14 | August 23, 2022, you aren't aware of any | |
| 15 | says, November 5, 2018. | 15 | other text messages with him that are not | |
| 16 | Do you see that? | 16 | included in the document? | |
| 17 | A
Yes. | 17 | A
Correct. | |
| 18 | Q
And then if you go to the very end | 18 | Q
Thank you. And you also said that | |
| 19 | of the document, the last message, as far as | 19 | you no longer have access to your emails; is | |
| 20 | I can tell, and you correct me if I'm wrong, | 20 | that correct? | |
| 21 | is dated Tuesday, August 23, 2022. | 21 | A
Correct. | |
| 22 | Is that your understanding? | 22 | Q
Can you just explain this a little | |
| 23 | A
Yes. | 23 | bit more detail -- strike that. | |
| 24 | Q
So outside of the text messages | 24 | Before asking that question. Did | |
| 25 | that are shown in this document, are you | 25 | you have email communications with | |
| | | | | |
| | Page 32 | | Page 33 | |
| | | | | |
| 1
2 | Mr. Krasner? | 1
2 | that, that would have gone via email. But | |
| 3 | A
Yes.
Q
Did you have email communications | 3 | the majority of the communication was on the
telephone or text. | |
| 4 | with anyone other than Mr. Krasner whom you | 4 | Q
Understood. And when you say you | |
| 5 | understood to be acting on behalf of Miles? | 5 | don't have access to these emails any | |
| 6 | MR. MAJOR: Objection to form. | 6 | longer, what does that mean exactly? | |
| 7 | A
No. | 7 | MR. MAJOR: Objection to form. | |
| 8 | Q
Do you have an approximate | 8 | A
When I left Coldwell Banker, they | |
| 9 | understanding of what the date range would | 9 | literally froze my email account the same | |
| 10 | have been for these emails that you had with | 10 | day, and I had no access to those emails. I | |
| 11 | Mr. Krasner, would it have been similar to | 11 | did contact the legal department of Coldwell | |
| 12 | these text messages? | 12 | Banker after I was first made aware that I | |
| 13 | A
Yes. | 13 | might have to be deposed. And they said, | |
| 14 | Q
What's the approximate volume of | 14 | yeah, they're gone. And it was well | |
| 15 | emails that you may have had with | 15 | after -- it was much more than a year after | |
| 16 | Mr. Krasner? | 16 | I left. And they said, you know, we | |
| 17 | MR. MAJOR: Objection to form. | 17 | generally get rid of them after nine months | |
| 18 | A
I generally used emails only to | 18 | or so. | |
| 19 | send potential properties, to alert upcoming | 19 | But he did say that Coldwell | |
| 20 | open houses or appointments, but all the | 20 | Banker had supplied whatever documents they | |
| 21 | details were generally covered in text. | 21 | had in the file with regards to the | |
| 22 | And so if he sent me something | 22 | transaction, the official documents, in | |
| 23 | like a signed document of some sort, like | 23 | other words, that I would have had and they | |
| 24
25 | the ones you have shown, exclusive right to
represent, and the exhibit and things like | 24
25 | would have had.
Q
Understood. So focusing back to | |
9 (Pages 30 to 33)
| | of 46 | | | | |
|----------|---------------------------------------------------------------------------------|--------|---------------------------------------------------------------------------------------------|--|--|
| | Page 34 | | Page 35 | | |
| 1 | Exhibit 3, the text message that you sent on | 1 | if Miles has an interest in seeing any of | | |
| 2 | November 5, 2018. It says here that: | 2 | the listings, is that generally consistent | | |
| 3 | "I am still waiting to get info on | 3 | with what you said before, that Mr. Krasner | | |
| 4 | other properties that may be perfect for | 4 | was acting on Miles' behalf in this process? | | |
| 5 | Miles but are not currently on the market." | 5 | MR. MAJOR: Objection to form. | | |
| 6 | Do you see that? | 6 | A
Yes. | | |
| 7 | A
Correct. Yes, I see that. | 7 | Q
And then in the next text message | | |
| 8 | Q
And then you say: | 8 | you say, and this is January 12, 2019, you | | |
| 9 | "I will get back as soon as I hear | 9 | say: | | |
| 10 | more. In the meantime, does Miles have an | 10 | "Max, we are confirmed for noon at | | |
| 11 | interest in seeing any of the listings that | 11 | 125 Pecksland. Still working on others." | | |
| 12 | I sent you last week." | 12 | He responds and says: "Okay. | | |
| 13 | Do you see that? | 13 | Thanks." And then in the next message from | | |
| 14 | A
Yes. | 14 | Mr. Krasner on January 12, it says, driver | | |
| 15 | Q
First of all, those listings that | 15 | name is Warren, there's a phone number. And | | |
| 16 | you sent last week, those would have been | 16 | then it says, "They will meet you at 125 | | |
| 17 | maybe listings that you sent via email? | 17 | Pecksland Road at noon." | | |
| 18 | A
Yes. They would have come from | 18 | Do you see that? | | |
| 19 | the MLS. There is an email function in the | 19 | A
Yes. | | |
| 20 | MLS that allows you to send properties as an | 20 | Q
I gather from this, correct me if | | |
| 21 | attachment, which are then openable and | 21 | I'm wrong, that 125 Pecksland Road was one | | |
| 22 | reviewable by the clients, with all the | 22 | of the properties you were showing Miles? | | |
| 23 | details of the listing. | 23 | A
Yes. | | |
| 24 | Q
Got it. And this message that you | 24 | Q
Was there a meeting that occurred | | |
| 25 | sent here, where you're asking Mr. Krasner | 25 | at that property? | | |
| | | | | | |
| | | | | | |
| | Page 36 | | Page 37 | | |
| | | | | | |
| 1 | A
Yes. | 1 | know. | | |
| 2 | Q
And this -- this message was dated | 2 | Q
Okay. The meeting whenever it | | |
| 3 | January 12, 2019, do you know when the | 3 | occurred, I think you already said this, but | | |
| 4 | meeting occurred? | 4 | Miles was present? | | |
| 5 | A
Probably January 12, but I would | 5 | A
Yes. | | |
| 6 | have to look up to see if that was a | 6 | Q
Did you look at just the 125 | | |
| 7 | Saturday or -- or -- but -- but from the | 7 | Pecksland Road property or did you look at | | |
| 8
9 | text messages I would -- I would say it | 8
9 | more properties? | | |
| 10 | happened on January 12, because that's the | 10 | A
I don't recollect the dates and so | | |
| 11 | morning where he confirmed that Miles was | 11 | forth, and so on of each individual showing. | | |
| 12 | going to look at the properties and that the | 12 | It's possible I would have shown him one or | | |
| | name of the driver was Warren. And his cell | 13 | two more that day, but the one that sticks | | |
| 13
14 | phone number in case I needed to get a hold | 14 | in my mind is the Pecksland property. If I | | |
| 15 | of him for a reason. But that was | 15 | look at my -- at the list of properties that
I did show him over time; it was 125 | | |
| 16 | definitely the first time I met Miles. | 16 | | | |
| 17 | Q
Okay. And -- and as you look
forward, and I'll get to this in a second, | 17 | Pecksland, 586 Round Hill, and 373 Taconic.
Those technically could have been around the | | |
| 18 | but the January 14, 2019 text messages says, | 18 | same time or even on the same date. | | |
| 19 | "Miles left his sunglasses in," it says | 19 | But I -- I don't have a strong | | |
| 20 | "bone." But I think he corrected that to | 20 | memory of exactly which property I showed | | |
| 21 | say, "one, of the properties yesterday." | 21 | out on that -- on that day. | | |
| 22 | If that's the January 14 and it | 22 | Q
Understood. Can you just describe | | |
| 23 | refers to yesterday, would that suggest that | 23 | for me what you recall about your | | |
| 24 | the meeting was on January 13th? | 24 | interactions with Miles on that day during | | |
| 25 | A
I don't know. I can't -- I don't | 25 | those visits? | | |
| of 46 | | | | |
|-------|-------------------------------------------------|----|----------------------------------------------------------------|--|
| | Page 38 | | Page 39 | |
| 1 | MR. MAJOR: Objection to form. | 1 | MR. MAJOR: Objection to form. | |
| 2 | A
He would go into each room and | 2 | A
Miles. | |
| 3 | view it like anyone else, and would make | 3 | Q
So you're understanding was that | |
| 4 | comments as to what he liked about it or | 4 | Miles would ultimately be making the | |
| 5 | didn't like about it. And as I said, I | 5 | decision? | |
| 6 | would then subsequently get more feedback | 6 | MR. MAJOR: Objection to form. | |
| 7 | from Max as to, you know, what he liked and | 7 | A
Yes. | |
| 8 | why, or didn't like and why. | 8 | Q
The text message says: | |
| 9 | Q
And did Miles ask you any | 9 | "Miles left his sunglasses in one | |
| 10 | questions at any point? | 10 | of the properties yesterday. He will pick | |
| 11 | A
Yes. | 11 | them up." | |
| 12 | Q
What types of questions? | 12 | It goes on: | |
| 13 | A
About the property. In almost | 13 | "Let me know if the glasses are | |
| 14 | every case there was a listing agent | 14 | found, he'll pick them up next time." | |
| 15 | present. So if he asked me a question and I | 15 | Do you see that? | |
| 16 | didn't know the answer, I would ask the | 16 | A
Yes. | |
| 17 | listing agent and give Miles the answer. | 17 | Q
So just to confirm, I -- does that | |
| 18 | Q
Okay. And what language was Miles | 18 | refresh your recollection that there were, | |
| 19 | speaking during these conversations? | 19 | in fact, multiple properties that would have | |
| 20 | A
English. | 20 | been shown at that time? | |
| 21 | Q
And based on these interactions, | 21 | A
Yes. | |
| 22 | what was your -- did you ever come to gain | 22 | Q
And then the January 14, 2019 text | |
| 23 | an impression as to who would ultimately be | 23 | message, that's the next one below that, | |
| 24 | making the decision as to whether or not to | 24 | that Mr. Krasner sent to you says, "Offer | |
| 25 | make an offer on a property? | 25 | 4 million on Taconic Road. I confirmed." | |
| | | | | |
| | | | | |
| | Page 40 | | Page 41 | |
| 1 | | 1 | | |
| 2 | Do you see that? | 2 | document, at the top there's a January 19, | |
| 3 | A
Yes.
Q
And "on Taconic road," do you | 3 | 2019 text message. It says:
"Emile, as we discussed, please | |
| 4 | understand that to be a reference to the 373 | 4 | respectfully explain to the owners our | |
| 5 | Taconic Road property? | 5 | situation. Miles said that it was a | |
| 6 | MR. MAJOR: Objection to form. | 6 | pleasure to meet such a nice family. Time | |
| 7 | A
Yes. | 7 | is of the essence and we are proposing the | |
| 8 | Q
Did you ever show Miles any other | 8 | following." | |
| 9 | properties on Taconic Road? | 9 | And then there's two proposals | |
| 10 | A
No. Not to my recollection. | 10 | listed. | |
| 11 | Q
Mr. Krasner said "I confirmed," | 11 | Couple of questions about this | |
| 12 | did you have an understanding of what he | 12 | message. | |
| 13 | meant there? | 13 | First of all, do you recall which | |
| 14 | MR. MAJOR: Objection to form. | 14 | property this message gives reference to? | |
| 15 | A
That I was instructed to offer | 15 | A
Wallacks Point. | |
| 16 | \$4 million for Taconic Road at the time. | 16 | Q
Okay. So was there a meeting that | |
| 17 | Q
Instructed by whom? | 17 | took place at that property? | |
| 18 | MR. MAJOR: Objection to form. | 18 | A
Yes. | |
| 19 | A
By Max at this point. | 19 | Q
And Miles was present? | |
| 20 | Q
Okay. And from whom did you | 20 | A
Yes. | |
| 21 | understand Mr. Krasner was taking his | 21 | Q
Was this at the -- on the same | |
| 22 | direction? | 22 | date that we were already talking when the | |
| 23 | MR. MAJOR: Objection to form. | 23 | other properties were shown or a different | |
| 24 | A
Miles. | 24 | date? | |
| 25 | Q
If you go the next page of the | 25 | A
No. Different. | |
11 (Pages 38 to 41)
| | of 46 | | |
|----------|-------------------------------------------------|----------|---------------------------------------------------------------------------------------|
| | Page 42 | | Page 43 |
| 1 | Q
Okay. And to the best of your | 1 | you have an understanding of why time was of |
| 2 | recollection, can you describe your | 2 | the essence for Miles? |
| 3 | interaction with Miles during that visit? | 3 | MR. MAJOR: Objection to form. |
| 4 | A
He came with the usual entourage; | 4 | A
No. Other than -- other than that |
| 5 | driver, security, et cetera, et cetera. And | 5 | he wanted it quickly, that's all. |
| 6 | I -- I believe his wife was there for this | 6 | Q
Okay. And like -- like the last |
| 7 | visit. If not the first visit, the second | 7 | visit he described, I assume Miles asked |
| 8 | visit. I believe they had two visits to | 8 | questions about the property during this |
| 9 | this property. One day and then the next | 9 | visit, et cetera? |
| 10 | day or a -- a day in between. | 10 | A
Yes. |
| 11 | And the asking price was | 11 | Q
And, again, what was the language |
| 12 | considerably higher. I believe 12 million | 12 | that was being spoken? |
| 13 | was the number. And they had some | 13 | A
English. |
| 14 | interaction with the sellers, the family | 14 | Q
In any of your interactions with |
| 15 | that lived there, which I think the message | 15 | Miles, did he ever have an interpreter |
| 16 | refers to. And he was very much interested | 16 | present? |
| 17 | in buying the property, but he wanted to do | 17 | MR. MAJOR: Objection to form. |
| 18 | it quickly and the family was not really | 18 | A
No. |
| 19 | able to make those short deadlines. | 19 | Q
So the language that was always |
| 20 | So his offer was based on a quick | 20 | spoken was English? |
| 21 | closing verses a slower closing for the same | 21 | A
Yes. |
| 22 | property. Subsequently, Miles decided | 22 | Q
I'd like to direct your attention |
| 23 | against buying and withdrew his offer. | 23 | to the text message in the middle of the |
| 24 | Q
Okay. And when it says "time is | 24 | page that's dated "February 11, 2020." |
| 25 | of the essence" and you eluded to that, do | 25 | Do you see that? |
| | | | |
| | | | |
| | Page 44 | | Page 45 |
| 1 | A
Yes. | 1 | A
My understanding was that he was |
| 2 | Q
And given that it's on the | 2 | not interested, not looking, not going, not |
| 3 | left-hand side, this would be a -- as you | 3 | focused on buying a house during that |
| 4 | discussed, a -- as you described, a message | 4 | period. And it was out of the clear blue |
| 5 | from Mr. Krasner and it says: | 5 | sky that he -- or that Max approached me |
| 6 | "Also, if you think there are | 6 | again and said, "Remember that house that |
| 7 | other properties that might interest Miles, | 7 | you showed Miles at 373 Taconic, it's -- is |
| 8 | please forward them and we will review | 8 | it still available, and what price, and can |
| 9 | them." | 9 | we see it?" |
| 10 | Do you see that? | 10 | Q
Got it. |
| 11 | A
Yes. | 11 | And so your message back to him |
| 12 | Q
So, my first question is: It -- I | 12 | says: |
| 13 | take it from the sequence of the message | 13 | "Max, we are confirmed for noon |
| 14 | here, and correct me if I'm wrong, that | 14 | today at 373 Taconic Road." |
| 15 | there was a -- basically, a more than | 15 | And then it says, "Also, walking |
| 16 | one-year gap in the text communications that | 16 | property at 371." |
| 17 | you had with Mr. Krasner from January 22, | 17 | So did a meeting occur on |
| 18 | 2019 to February 11, 2020; is that right? | 18 | February 11, at 373 Taconic Road? |
| 19 | A
Correct. | 19 | A
Yes. |
| 20 | MR. MAJOR: Objection to form. | 20 | Q
And was Miles present at that |
| 21 | Q
What -- what was you understanding | 21 | meeting? |
| 22 | for why the process or the communication at | 22 | A
Yes. |
| 23
24 | least according to this, stopped for a year, | 23
24 | Q
And to the best of your |
| 25 | approximately?
MR. MAJOR: Objection to form. | 25 | recollection, can you just describe to me
what occurred during that meeting at 373 |
12 (Pages 42 to 45)
| of 46 | |
|---------|--|
| Page 46 | |
| | Page 46 | | Page 47 |
|----|---------------------------------------------|----|----------------------------------------------|
| 1 | Taconic? | 1 | MR. MAJOR: Objection to form. |
| 2 | MR. MAJOR: Objection to form. | 2 | A
Miles. |
| | | 3 | |
| 3 | A
The property price had been | | Q
And -- and, again, how -- how did |
| 4 | lowered from my recollection, closer to | 4 | you come to have that understanding? |
| 5 | 5 million and Max decided to make an offer | 5 | MR. MAJOR: Objection to form. |
| 6 | the same day. And the price offered was | 6 | A
Well, he told me what he was |
| 7 | 4.6 million, which was accepted by the | 7 | willing to offer in English. |
| 8 | sellers, and the real estate person | 8 | Q
Miles told you what he was willing |
| 9 | representing the sellers acknowledged that. | 9 | to offer? |
| 10 | Q
I think you just said that Max | 10 | A
Yes. And it was confirmed, the |
| 11 | decided to make an offer. Was it your | 11 | details were confirmed by -- by Max, in this |
| 12 | understanding that Max was the | 12 | case. But this was a transaction that went |
| 13 | decision-maker? | 13 | unusually quick. I mean, the offer was made |
| 14 | MR. MAJOR: Objection to form. | 14 | on Monday and the closing took place on |
| 15 | A
Yes. | 15 | Friday of the same week. And the moving |
| 16 | Q
Max not Miles? | 16 | trucks were in the driveway waiting for the |
| 17 | A
Sorry. | 17 | money to clear and the lawyers to tell me |
| 18 | MR. MAJOR: Objection to form. | 18 | that they had closed. |
| 19 | A
No. The decision-maker was never | 19 | Q
What was your understanding of why |
| 20 | Max it was always Miles, but the | 20 | this transaction occurred so quickly? |
| 21 | communicator of Miles' intentions was | 21 | MR. MAJOR: Objection to form. |
| 22 | generally Max. | 22 | A
I had no information, other than |
| 23 | Q
Okay. So who did you understand | 23 | that Miles generally wanted things done |
| 24 | | 24 | |
| | had made the decision to make this offer on | | quickly and, you know, and wanted it done as |
| 25 | 373 Taconic Road? | 25 | fast as possible, that's it. That's all. |
| | | | |
| | | | |
| | Page 48 | | Page 49 |
| | | | |
| 1 | MR. BASSETT: I think we've | 1 | corner, first page. |
| 2 | been going about an hour. I'd like | 2 | Q
Mr. de Neree, do you recognize |
| 3 | to take a quick break. Why don't we | 3 | this document? |
| 4 | do that now for five or 10 minutes. | 4 | A
Yes. |
| 5 | VIDEOGRAPHER: We are now | 5 | Q
What is it? |
| 6 | going off the record. The time is | 6 | A
It's an offer to purchase real |
| 7 | 11:11. | 7 | estate. |
| 8 | (Whereupon, a recess was taken | 8 | Q
Offer to purchase which real |
| 9 | from 11:11 AM to 11:23 AM.) | 9 | estate? |
| 10 | VIDEOGRAPHER: We are now back | 10 | A
373 Taconic Road. |
| 11 | on the record. The time is 11:23. | 11 | Q
And prior to break, we were |
| 12 | Q
Mr. de Neree, I want to show you a | 12 | discussing the offer that Miles made on this |
| 13 | couple of additional documents. If I could | 13 | property. Do you recall that? |
| 14 | have my colleague put Tab 4 into the chat, | 14 | A
Yes. |
| 15 | please. | 15 | MR. MAJOR: Objection to form. |
| 16 | (Whereupon, Offer to Purchase | 16 | Q
Is this the formal offer related |
| 17 | Real Estate (GREE02327) was | 17 | to that offer for this property? |
| 18 | marked as Exhibit 4 for | 18 | MR. MAJOR: Objection to form. |
| 19 | identification as of this date.) | 19 | A
Yeah, it's a nonbinding offer to |
| 20 | MR. BASSETT: I'd like the | 20 | purchase, which generally becomes the deal |
| 21 | court reporter to please mark this | 21 | term for the lawyers to put together a |
| 22 | document as de Neree Exhibit 4. | 22 | contract. |
| 23 | For the record, this is a | 23 | Q
Understood. |
| 24 | document with the Bates Label | 24 | It's dated February 11, 2020; is |
| 25 | GREE002327, bottom of the right-hand | 25 | that right? |
13 (Pages 46 to 49)
Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 15
| | of 46 | | |
|--------|------------------------------------------------------------|--------|---------------------------------------------------|
| | Page 50 | | Page 51 |
| 1 | A
Correct. | 1 | Q
And did that understanding change |
| 2 | Q
Okay. And it says -- where it | 2 | based on the fact that the named buying |
| 3 | says "buyer" it says "Greenwich Land, LLC." | 3 | entity was Greenwich Land, LLC? |
| 4 | Do you see that? | 4 | MR. MAJOR: Objection to form. |
| 5 | A
Correct. | 5 | A
Correct. |
| 6 | Q
Do you have any understanding of | 6 | Q
You're understanding did not |
| 7 | why the buyer was Greenwich Land, LLC? | 7 | change? |
| 8 | MR. MAJOR: Objection to form. | 8 | MR. MAJOR: Objection to form. |
| 9 | A
No. I mean, it, as I said, it's | 9 | A
Can you rephrase the question so |
| 10 | not unusual for the buyers in the Greenwich | 10 | it's easier for me to answer. |
| 11 | or elsewhere for that matter, to -- to buy a | 11 | Q
Earlier you testified that Miles |
| 12 | property in an LLC. | 12 | was the one who made the decision to buy the |
| 13 | Q
Did you ask what the relationship | 13 | property, correct? |
| 14 | was between Greenwich Land, LLC and Miles? | 14 | A
Yes. |
| 15 | MR. MAJOR: Objection to form. | 15 | Q
This offer to purchase real estate |
| 16 | A
No. I didn't because I was | 16 | as a buyer in Greenwich Land, LLC., right? |
| 17 | instructed by Max that would be the buyer. | 17 | A
Yes. |
| 18 | They would put it in an LLC named Greenwich | 18 | Q
So do you understand that |
| 19 | Land. | 19 | Greenwich Land, LLC., was the entity that |
| 20 | Q
And before you testified that you | 20 | Miles was using to purchase the property? |
| 21 | understood that Miles was the one making a | 21 | MR. MAJOR: Objection to form. |
| 22 | decision to the buy the property; is that | 22 | A
Yes. |
| 23 | right? | 23 | MR. BASSETT: Could my |
| 24 | MR. MAJOR: Objection to form. | 24 | colleagues please put our Tab 6 on |
| 25 | A
Correct. | 25 | the screen, please. |
| | | | |
| | | | |
| | Page 52 | | Page 53 |
| | | | |
| 1 | (Whereupon, Email (WBAM_009051) | 1 | A
Yes. |
| 2 | was marked as Exhibit 5 for | 2 | Q
And if you look at -- if you look |
| 3 | identification as of this date.) | 3 | at the email from the Julie Burke, which is |
| 4
5 | MR. BASSETT: I'll have the | 4 | at the bottom of the second page, dated |
| 6 | court reporter please mark this as | 5 | August 1, 2020 with the subject line 373 |
| 7 | de Neree Exhibit 5.
Q
Mr. de Neree, before I ask you | 6
7 | Taconic Road, this is an email from her to |
| 8 | questions about this document, when was the | 8 | you. This would have been after the closing |
| 9 | first time you ever heard the name Greenwich | 9 | of the purchase of 373 Taconic Road, |
| 10 | Land, LLC.? | 10 | correct?
A
August 1, 2020, yes, absolutely. |
| 11 | A
On that day. On that very day | 11 | I'm just reading the email. |
| 12 | that they instructed me to make an offer. | 12 | Q
Yeah. |
| 13 | Q
So the email that -- sorry. The | 13 | A
Yeah. |
| 14 | document that's been marked as de Neree | 14 | Q
Just to paraphrase he's |
| 15 | Exhibit 5, for the record, Bates label at | 15 | essentially saying that the sellers are |
| 16 | the bottom right-hand corner of the first | 16 | asking for certain funds that are still |
| 17 | page WBAM_009051. And you can take your | 17 | being held in escrow to be released, is that |
| 18 | time to scroll through the whole thing, but | 18 | generally what she's saying here? |
| 19 | do you recognize this document, Mr. de | 19 | MR. MAJOR: Objection to form. |
| 20 | Neree? | 20 | A
Yes. |
| 21 | A
Yes. | 21 | Q
Then if you go up to the next |
| 22 | Q
And is it correct that this is an | 22 | email dated August 19, 2020 you say: |
| 23 | email chain involving you, Mr. Krasner, a | 23 | "Dear Margaret and Max, the |
| 24 | Margaret Conboy and at times some other | 24 | sellers for 373 Taconic, which was bought by |
| 25 | individuals? | 25 | Miles under Greenwich Land, are asking that |
14 (Pages 50 to 53)
| | of 46 | | |
|----------|----------------------------------------------|----------|---------------------------------------------------|
| | Page 54 | | Page 55 |
| 1 | the escrow accounts be release." | 1 | assistant. |
| 2 | Do you see that? | 2 | Q
I'd like to direct your attention |
| 3 | A
I'm looking. Is it up above it. | 3 | back the Exhibit 3, which are the text |
| 4 | Yeah, it's above this, yes, yeah. | 4 | messages. |
| 5 | Q
And you say 373 Taconic. | 5 | A
Yeah. |
| 6 | "Which was bought by Miles under | 6 | Q
If you go to -- I'm sorry, we |
| 7 | Greenwich Land." | 7 | |
| 8 | | 8 | don't have page numbers. I'm going to a |
| | I just want to focus on that. Do | | text message that's dated February 15, 2020. |
| 9 | you see that? | 9 | A
15, 2020, yeah. |
| 10 | A
Yeah. | 10 | Q
Actually, before, I apologize, |
| 11 | Q
Was that an accurate statement | 11 | just sort of put a pin in that if we could. |
| 12 | that you wrote in this email? | 12 | Before we go there I want to just show you |
| 13 | MR. MAJOR: Objection to form. | 13 | one more document. If my colleague could |
| 14 | A
Yes. | 14 | please put into the chat our Tab 5. |
| 15 | Q
So it's your understanding that | 15 | (Whereupon, Residential Real |
| 16 | Miles bought 373 Taconic under Greenwich | 16 | Estate Sales Agreement |
| 17 | Land, LLC.? | 17 | (GREE02328) was marked as |
| 18 | MR. MAJOR: Objection to form. | 18 | Exhibit 6 for identification as |
| 19 | A
That was my understanding. | 19 | of this date.) |
| 20 | Q
And again, how did you come to | 20 | A
Got it. |
| 21 | that understanding? | 21 | MR. BASSETT: And for the |
| 22 | MR. MAJOR: Objection to form. | 22 | record, I'll have this marked as de |
| 23 | A
He was the one that told me that | 23 | Neere Exhibit 6. Starts at the |
| 24 | he wanted it, how much he was going to offer | 24 | bottom right-hand corner with the |
| 25 | and all the details were handled by his | 25 | first page with the Bates label |
| | | | |
| | Page 56 | | Page 57 |
| | | | |
| 1 | GREE002328. | 1 | "Yes, 373 Taconic. Call Matthew, |
| 2 | Q
We already just looked at, which | 2 | the security." |
| 3 | was de Neere Exhibit 4, the offer for the | 3 | Do you see that? |
| 4 | property at 373 Taconic Road. Is this the | 4 | A
Yes. |
| 5 | formal sales agreement that followed? | 5 | Q
So this would have been after the |
| 6 | A
Yeah. That's the contract. | 6 | purchase agreement was executed before the |
| 7 | Q
Okay. And this was dated | 7 | closing; is that correct? |
| 8 | February 14, 2020; is that right? | 8 | A
Yes. |
| 9 | A
Correct. | 9 | Q
And then the meeting in fact |
| 10 | Q
Is that the same -- is that the | 10 | occurred at the house February 15, 2020, to |
| 11 | date of closing? Actually, if you look at | 11 | your recollection? |
| 12 | next page closing it says February 21, 2020? | 12 | A
Yes. |
| 13 | A
Yeah, that sounds right. | 13 | MR. MAJOR: Objection to form. |
| 14 | Q
Now back to Exhibit 3 -- or, | 14 | Q
What was the purpose of that |
| 15 | sorry, not Exhibit 3 -- yes, Exhibit 3, the | 15 | meeting? |
| 16 | text messages, back to that | 16 | A
The purpose was to -- to the meet |
| 17 | February 15, 2020 email, not email, text | 17 | with designers, in this case it was an |
| 18 | message. I think there's only one text | 18 | interior designer and an architect, someone |
| 19 | message on that date from you to Max Krasner | 19 | specializing in high-end renovations and he |
| 20 | which says: | 20 | wanted to meet them about some changes he |
| 21 | "Max, are we still on for noon | 21 | wanted to make to the house. |
| 22 | today at 373 Taconic?" | 22 | Q
You're saying he, who are you |
| 23 | Do you see that? | 23 | referring to? |
| 24
25 | A
Yes, correct.
Q
Then he says: | 24
25 | A
Miles.
Q
So Miles was at this meeting? |
15 (Pages 54 to 57)
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| | Case 22-50073 | Doc 2292-39
Filed 10/26/23
of 46 | | Entered 10/26/23 20:46:12 | Page 17 |
|----|---------------|----------------------------------------------|----|----------------------------------------------|---------|
| | | Page 58 | | | Page 59 |
| 1 | A | Correct. | 1 | on, and he took them through the house and I | |
| 2 | Q | And then architects or designers | 2 | wasn't present in every discussion and every | |
| 3 | | were at this meeting? | 3 | aspect of the changes that he was talking | |
| 4 | A | Correct. | 4 | about. | |
| 5 | Q | You were there, too? | 5 | Q
Okay. After this | |
| 6 | A | Yes, I wasn't in the meeting from | 6 | February 15, 2020 meeting, are you aware of | |
| 7 | | beginning to end, but I was present and | 7 | any other meetings that occurred at the 373 | |
| 8 | | introduced them and so forth. | 8 | Taconic Road property? | |
| 9 | Q | The parts that you did observe, | 9 | MR. MAJOR: Objection to form. | |
| 10 | | can you describe generally the interactions | 10 | A
I'm trying to see the dates. | |
| 11 | | that occurred between Miles and the | 11 | 17th. I believe at most of the meetings | |
| 12 | | designers and architects? | 12 | that I had at the property were with | |
| 13 | | MR. MAJOR: Objection to form. | 13 | inspectors and property managers, previous | |
| 14 | Q | You said you were present for part | 14 | property managers and things like that. | |
| 15 | | of the meeting, correct? | 15 | Just for the purpose of a building | |
| 16 | A | Correct. | 16 | inspection report. | |
| 17 | Q | The parts that you were present | 17 | Q
Did you recall ever meeting Miles | |
| 18 | | for, can you please describe generally, the | 18 | at the property after that February 2020 | |
| 19 | | interactions that you observed between Miles | 19 | meeting? | |
| 20 | | and the architects and designers? | 20 | A
I'm just looking at my agenda to | |
| 21 | | MR. MAJOR: Objection as to | 21 | see if I can find some clarification. But | |
| 22 | | form. | 22 | the closing itself -- so on the 17th it was | |
| 23 | A | He talked about what he liked and | 23 | just me and the seller's agent. On the | |
| 24 | | what he didn't like and what had changed and | 24 | 17th. I have meeting with the moving | |
| 25 | | how was that possible and so forth and so | 25 | company on the 18th. | |
| | | Page 60 | | | Page 61 |
| 1 | Q | Mr. de Neree, are you looking at a | 1 | "Hi, Max I have a scheduled | |
| | | | | | |
| 1 | Q
Mr. de Neree, are you looking at a | 1 | "Hi, Max I have a scheduled |
|----|----------------------------------------------|----|----------------------------------------------|
| 2 | calender or a personal -- | 2 | showing at 429 Taconic." |
| 3 | A
My own calender, yeah, I don't | 3 | Do you see that? |
| 4 | write down everything, but a few things. It | 4 | A
Yeah. |
| 5 | says moving company at 373 Taconic and I'm | 5 | Q
Yes, it says: |
| 6 | only going by what I was doing that day. | 6 | "Hi, Max, I have scheduled a |
| 7 | But I don't have everything. | 7 | showing at 429 Taconic at 2:00 p.m., Friday, |
| 8 | Q
And that's fine. So Mr. de Neree, | 8 | it's the horse farm property up the road |
| 9 | I think, I don't think we have that document | 9 | from Miles home and he wanted to see it." |
| 10 | and I believe to the extent that agenda or | 10 | Do you see that? |
| 11 | calender of yours, to the extent that it | 11 | A
Yes. |
| 12 | refer to meetings at the property, it | 12 | Q
So what was this text message |
| 13 | probably would be technically responsive to | 13 | about? |
| 14 | our subpoena. I would ask you to provide a | 14 | MR. MAJOR: Objection to form. |
| 15 | copy of that after this, but obviously we | 15 | A
Well, as it says, Miles had |
| 16 | can redact it so that you don't have | 16 | expressed an interest either directly to me |
| 17 | personal stuff in there or whatever, but we | 17 | or via Max, I do not remember because I sent |
| 18 | can talk about that after the deposition | 18 | him information about this and it confirms |
| 19 | today. | 19 | that I set up the appointment for 2:00 p.m. |
| 20 | A
Okay. | 20 | on Friday. |
| 21 | Q
If you could go to a couple of | 21 | Q
So after purchasing 373 Taconic, |
| 22 | pages in Exhibit 3, down from where we were | 22 | Miles was interested in potentially buying |
| 23 | for the March 5th, 2020 text messages. Text | 23 | other nearby properties? |
| 24 | message from you to Mr. Krasner, it starts | 24 | MR. MAJOR: Objection to form. |
| 25 | with: | 25 | A
Yes. |
| | | | |
| | of 46 | | |
|--------|-----------------------------------------------------------------------------------------|--------|----------------------------------------------|
| | Page 62 | | Page 63 |
| 1 | Q
And when you said up the road for | 1 | the communication. |
| 2 | Miles home, did you mean to say up the road | 2 | Q
Okay. If you can go to the next |
| 3 | from Miles home? | 3 | page, the May 21, 2020 text message it says: |
| 4 | A
Yes. | 4 | "Hi, Max. Gladys reaches out to |
| 5 | MR. MAJOR: Objection to form. | 5 | me to find office space or farm near Indian |
| 6 | Q
When you said Miles home, what | 6 | Harbor for Miles." |
| 7 | were you referring to? | 7 | Do you see that? |
| 8 | A
373 Taconic. | 8 | A
Yes. |
| 9 | MR. MAJOR: Objection to form. | 9 | Q
Who is Gladys? |
| 10 | Q
Also, you say here that when | 10 | A
Gladys introduced herself as |
| 11 | you're referring to 429 Taconic that, this | 11 | working for Miles and looking for office |
| 12 | is the last line of the second sentence that | 12 | space. |
| 13 | quote: | 13 | Q
Do you know her last name? |
| 14 | "He wanted to see it." | 14 | A
No. |
| 15 | Who is he in reference to? | 15 | Q
She said she worked for Miles? |
| 16 | A
Miles. | 16 | A
Yes. |
| 17 | Q
How did you know that he wanted to | 17 | Q
What she told you was that Miles |
| 18 | see the home? | 18 | was looking to acquire office space or farm |
| 19 | A
Because he told me so. | 19 | near Indian Harbor? |
| 20 | Q
Miles? | 20 | A
Yeah, that he had an interest in |
| 21 | A
Yes. That's what I surmised from | 21 | it, yeah. |
| 22 | the message because I don't remember whether | 22 | Q
Did you come to have any |
| 23 | Max first said that Miles wanted to see it. | 23 | understanding for what purpose he was |
| 24 | Or whether Miles told me directly that he | 24 | looking for this office space? |
| 25 | wanted to see it. Again, I do not remember | 25 | A
No. I mean office space, to work |
| | | | |
| | Page 64 | | Page 65 |
| 1 | out of I imagine. | 1 | may not have any other questions at |
| | | | |
| | | | |
| 2 | Q
What about a farm, any | 2 | this time, but let me confirm that |
| 3 | understanding of why he was looking to | 3
4 | and then I'll let you know when we |
| 4 | acquire a farm? | 5 | get back on. |
| 5
6 | MR. MAJOR: Objection to form. | 6 | MR. MAJOR: Okay.
VIDEOGRAPHER: We are now |
| 7 | A
No. He was looking for a good, I | 7 | going off the record. The time is |
| 8 | guess land investment that had a farm on it.
Not necessarily working farm, he wasn't | 8 | 11:50. |
| 9 | looking at that necessarily. But he looked | 9 | (Whereupon, a recess was taken |
| 10 | at property that was beautiful and large, | 10 | from 11:50 AM to 12:04 PM.) |
| 11 | multiple acres overlooking with good views | 11 | VIDEOGRAPHER: We are now back |
| 12 | and nice stream through it and that was | 12 | on the record, the time is 11:54. |
| 13 | about it. That's the information I got. | 13 | MR. BASSETT: So, Mr. de |
| 14 | And there weren't very many properties like | 14 | Neree, thank you again for your time |
| 15 | that available at the time except for the | 15 | this morning. I do not have any |
| 16 | one up the road, which I described was | 16 | other questions right now, although |
| 17 | 14 million, he liked it, but he just thought | 17 | I do reserve the right to ask some |
| 18 | it was too much money. | 18 | followup questions after Mr. Major |
| 19 | Q
Understood. Did you ever end up | 19 | asks his questions. So at this time |
| 20 | helping Miles actually buy and close on the | 20 | I will pass the witness. |
| 21 | purchase of any other properties? | 21 | EXAMINATION BY |
| 22 | A
No. | 22 | MR. MAJOR: |
| 23 | MR. MAJOR: Objection to form. | 23 | Q
Good afternoon, Mr. de Neree, my |
| 24 | MR. BASSETT: Can we take | 24 | name is Chris Major. I'm at the law firm |
| 25 | another five to 10 minutes again. I | 25 | Meister, Seelig & Fein. We represent the |
17 (Pages 62 to 65)
| | of 46 | | |
|----|----------------------------------------------|----|----------------------------------------------|
| | Page 66 | | Page 67 |
| 1 | defendants in the adversary proceeding, Hing | 1 | form. |
| 2 | Chi Ngok and Greenwich Land, LLC. I've got | 2 | A
I'm just closing that so I can |
| 3 | some questions for you covering some of the | 3 | see, no, only that there's a bankruptcy |
| 4 | subject matter you've testified to today and | 4 | proceeding involving this property and |
| 5 | some other questions for you as well. So | 5 | others, that's all. |
| 6 | that and the same ground rules will apply so | 6 | Q
When you say there's a bankruptcy |
| 7 | please let me finish my question before you | 7 | involving this property, what do you mean by |
| 8 | start your answer and Mr. Bassett, who's | 8 | that? |
| 9 | representing the Chapter 11 Trustee in this | 9 | A
I -- just that there is a |
| 10 | case, he may have objections to some of my | 10 | bankruptcy involving Miles and that's what I |
| 11 | questions. Are those ground rules okay with | 11 | was told, and this property's involved and I |
| 12 | you? | 12 | don't know what other properties could be |
| 13 | A
Yes. | 13 | involved, I have no other knowledge of |
| 14 | Q
Okay. I want to give you one | 14 | anything else. |
| 15 | other very important instruction, which is | 15 | Q
Who told you that there was a |
| 16 | you have been called to testify at this | 16 | bankruptcy involving Miles? |
| 17 | deposition as a fact witness and for that | 17 | A
I was told by Paul Hastings, I |
| 18 | reason, I want to ask you not to speculate | 18 | believe at one point they contacted me. |
| 19 | or assume things, but only testify to facts | 19 | Q
What is Paul Hastings? |
| 20 | that you actually know and know directly, is | 20 | A
The law firm Paul Hastings. |
| 21 | that okay? | 21 | Q
Okay. Do you know who the |
| 22 | A
Yes. | 22 | plaintiff is in the lawsuit in which you're |
| 23 | Q
Okay. First of all, do you know | 23 | testifying? |
| 24 | anything about what this case is about? | 24 | A
I mean I don't know. No, I don't |
| 25 | MR. BASSETT: Objection to | 25 | know for sure. The state is it? I don't |
| | Page 68 | | Page 69 |
| 1 | know. I do not know. | 1 | Q
What, if anything, did you do to |
| 2 | Q
You've been referring to someone | 2 | confirm his identity during the time you had |
| 3 | named Miles today. Do you know that | 3 | in-person meetings with the person you refer |
| 4 | person's full name? | 4 | to as Miles? |
| 5 | A
He was always referred to me as | 5 | A
I did not have any attempt to |
| 6 | Miles. He introduced himself as Miles. I | 6 | identify him. |
| 7 | didn't know his full name. I found out that | 7 | Q
Do you know whether the person |
| 8 | he had a last name later, after I met him. | 8 | you've been referring to as Miles was |
| 9 | And did not know that he had other names | 9 | married? |
| 10 | that he went by, and I did not know some of | 10 | A
Yes. |
| 11 | the names that were mentioned earlier in the | 11 | Q
Do you know whether he had |
| 12 | deposition. | 12 | children? |
| 13 | Q
You said you found out later that | 13 | A
Yes. |
| 14 | he went by other names. Is that what you | 14 | Q
Do you know the names of the |
| 15 | just said? | 15 | children? |
| 16 | A
Yeah. There were stories on the | 16 | A
I don't remember. I must have |
| 17 | internet and more recently stories that came | 17 | known them at some point, but they may have |
| 18 | out about Miles, where he was named -- where | 18 | been introduced to me with their first |
| 19 | he had other names that he supposedly had | 19 | names. But I don't remember their names. I |
| 20 | been using. But I did not know those names | 20 | met his wife twice. Once at Wallacks Point |
| 21 | and I never heard those before. | 21 | during the negotiation about that property. |
| 22 | Q
Did you ever see any government | 22 | And the second time I believe was at 373 |
| 23 | issued photo identification of the person | 23 | Taconic with her two, one daughter, one son. |
| 24 | you knew as Miles? | 24 | Q
Do you speak Mandarin? |
| 25 | A
No. | 25 | A
No. I do not. |
| | | | |
| Case 22-50073 | Doc 2292-39
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of 46 | | Entered 10/26/23 20:46:12
Page 20 |
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| | Page 70 | | Page 71 |
| 1 | Q
So you would not understand a | 1 | place? |
| 2 | conversation if it took place in front of | 2 | A
I do not recall. |
| 3 | you but in Mandarin? | 3 | Q
Was it during 2023? |
| 4 | MR. BASSETT: Objection to | 4 | A
We're in August, it could have |
| 5 | form. | 5 | taken place in '23. Honestly, it was a |
| 6 | A
I would not. | 6 | phone call. I had no notes of it or |
| 7 | Q
You mentioned the law firm Paul | 7 | anything, just to -- |
| 8 | Hastings. When was the first time you spoke | 8 | Q
Do you know whether anyone else |
| 9 | with someone from Paul Hastings regarding | 9 | was on the line when Mr. Despins called you? |
| 10 | Miles or the bankruptcy or any property, | 10 | A
No. |
| 11 | including but not limited to 373 Taconic | 11 | Q
Have you spoken with anyone else |
| 12 | Road? | 12 | before today from Paul Hastings? |
| 13 | A
Well, I was approached at one | 13 | A
About this matter? |
| 14 | point by Luc, Luc, last name -- I think it | 14 | Q
Yes. |
| 15 | was Lapin [sic]. And he mentioned that he | 15 | A
I believe all communication from |
| 16 | was in charge of the bankruptcy. No details | 16 | that point were in emails and notifications |
| 17 | on that, but just in case. And he said, | 17 | like that. I got served a subpoena to |
| 18 | your name has come up as having done | 18 | appear three times, I think. Once in |
| 19 | business with this person Miles. And he | 19 | Bridgeport, once in Stamford, and once in |
| 20 | said, we may have to depose you sometime in | 20 | New York City. And none of them ever |
| 21 | the future. And I said, fine. I mean, you | 21 | happened. I even went to New York City when |
| 22 | know, that was about it. So it was the | 22 | I wasn't needed. It didn't happen, in other |
| 23 | first I heard that there could be a | 23 | words. |
| 24 | deposition. | 24 | Q
Okay. Do you have the emails that |
| 25 | Q
When did that conversation take | 25 | you've exchanged with Paul Hastings? |
| | Page 72 | | Page 73 |
| 1
A
I had no exchange. It was just
1
A
I don't even know what --
2
2
notified. I didn't get back. Oh, the only
Q
Sure. Are you a lawyer?
3
3
ones were the most recent ones that I saw
A
No. I'm not. I'm a realtor.
4
you guys were copied on, just having to do
4
Q
Understood. The docket is just a
5
5
with the timing of the deposition and that
list of documents that have been filed in
6
6
it was going to be a Zoom as opposed to an
the case and notices and things like that. |
|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| |
| |
| |
| |
| |
| |
| 7
in-person and exactly when. That's it.
7
A
No, no. I have not. |
| 8
8
That's the only communication that I have
Q
So presumably, someone had to tell |
| 9
9
about the -- and the other ones were just,
you that you were not needed at the |
| 10
as I said, you know, official documents,
10
courthouse in Bridgeport as set forth in the |
| 11
11
subpoena to appear and stuff.
subpoena, right? |
| 12
12
Q
You mentioned that you were
A
Correct. |
| 13
subpoenaed to appear in Bridgeport. Was
13
Q
Was that someone from Paul |
| 14
14
that at a courthouse?
Hastings? |
| 15
15
A
Yes.
A
I believe so. |
| 16
Q
Did you go to the courthouse?
16
Q
Do you know what the name of that |
| 17
17
A
No. Everything was canceled prior
person was? |
| 18
18
to, you know, everything was canceled.
A
Well, the most recent |
| 19
Q
Have you ever looked at the docket
19
communications were all with Avi Luft. I've |
| 20
20
in this case?
never met Avi Luft, but that's just a person |
| 21
21
MR. BASSETT: Objection to
that from whom I got communication. |
| 22
22
form.
Q
Did the person from Paul Hastings |
| 23
23
A
No. I have not. What do you mean
tell you why your presence was not required |
| 24
by "the docket"?
24
at the Bridgeport courthouse? |
| 25
25
Q
Had you ever --
A
No. Just that it was postponed |
| |
19 (Pages 70 to 73)
| | of 46 | | |
|----------|-----------------------------------------------------------------------------------------|----------|----------------------------------------------------------|
| | Page 74 | | Page 75 |
| 1 | canceled, whatever, push forward, timing, | 1 | have to look that up. I don't know. Just |
| 2 | whatever. No. No reason. | 2 | by memory. |
| 3 | Q
When Mr. Despins called you for | 3 | Q
Okay. You also mentioned that you |
| 4 | the first time, what did he tell you about | 4 | received a subpoena to show up in New York |
| 5 | the case? | 5 | City, correct? |
| 6 | MR. BASSETT: Object to form. | 6 | A
Yes. |
| 7 | A
As I said, he said, we've seen | 7 | Q
And I think you were starting to |
| 8 | your name on documents involving the | 8 | say that you actually traveled to New York |
| 9 | purchase of 373 Taconic, and it's involved | 9 | City pursuant to that subpoena; is that |
| 10 | in a bankruptcy proceeding. No details | 10 | correct? |
| 11 | there, but -- | 11 | A
Yes. Because I think I was -- if |
| 12 | And, as I said, he said, we may | 12 | I recall, I was served, somebody came to my |
| 13 | have to subpoena you or you may have to | 13 | house with a subpoena, I was served. The |
| 14 | testify or something like that. I don't | 14 | date was whatever. I decided head into the |
| 15 | recall what he said exactly, but something | 15 | city. And then I called the firm to confirm |
| 16 | along those lines. And I said, well, I hope | 16 | the details of timing and where to go and so |
| 17 | not. But other than that, you know. | 17 | forth and so on. And they said no, no, no, |
| 18 | Q
You mentioned that you were once | 18 | there's no deposition today, and there's |
| 19 | subpoenaed to show up in Stamford, | 19 | no -- so, apologies, but, no, it's not |
| 20 | Connecticut, I believe, right? | 20 | happening today. |
| 21 | A
Well, I would have to look at the | 21 | Q
Do you recall when that was? |
| 22 | details. But, as I said, there were several | 22 | A
When that was? |
| 23 | locations. The first one I believe was | 23 | Q
Yes. |
| 24 | Bridgeport. And the second one was a | 24 | A
My best recollection, somewhere in |
| 25 | location I thought in Stamford, but I would | 25 | May or June. |
| | | | |
| | | | |
| | Page 76 | | Page 77 |
| | | | |
| 1 | Q
Of 2023? | 1 | around and went home. |
| 2 | A
Yes. This year. Yeah. That was | 2 | Q
Did you turn around after you got |
| 3 | the last one that was canceled, I believe. | 3 | to Grand Central? |
| 4 | Q
Do you have a copy of that | 4 | A
Right. I took the next train back |
| 5 | subpoena? | 5 | to Stamford. |
| 6 | A
I must have somewhere, but I don't | 6 | Q
Do you recall who at Paul Hastings |
| 7 | know. Here it is. Yes. I'll show you the | 7 | you spoke with? |
| 8 | document right here. It says 10:00 a.m. on | 8 | A
No. I don't remember who I spoke |
| 9 | May 12, and the location is Paul Hastings. | 9 | with. It could have been Avi or -- I don't |
| 10 | Q
Can you determine from looking at | 10 | remember. Or it could have been Luc Lapin |
| 11 | it who signed that subpoena on behalf of | 11 | (sic). But I don't remember the specific |
| 12 | Paul Hastings? | 12 | conversation, other than, sorry, it's a |
| 13 | MR. BASSETT: Objection. | 13 | mistake and we're not having it. |
| 14 | A
No. It has a scratch. I mean, | 14 | Q
Before you traveled to New York |
| 15 | you can tell for yourself. | 15 | City that day, you had spoken with |
| 16 | Q
Could I ask you to hold that up | 16 | Mr. Despins, right? |
| 17 | again, sir, please. | 17 | A
Yes. But that was a long time |
| 18 | A
(Witness complies.) | 18 | before that. |
| 19 | Q
Did you contact anyone at Paul | 19 | Q
Had you spoken with Mr. Luft |
| 20 | Hastings after receiving that subpoena? | 20 | before traveling to New York City that day? |
| 21 | A
Yeah. As I said, I contacted | 21 | A
I don't think so. |
| 22 | somebody to find out where to go and which | 22 | Q
And you can't determine from |
| 23 | room and so forth and so on. And they said, | 23 | looking at the subpoena that's in front of |
| 24
25 | we're so sorry, but this was a mistake and
there is no deposition today. So I turned | 24
25 | you, who signed it on behalf of Paul
Hastings, right? |
20 (Pages 74 to 77)
| | of 46 | | |
|----|----------------------------------------------|----|----------------------------------------------|
| | Page 78 | | Page 79 |
| 1 | MR. BASSETT: Objection. | 1 | A
That was it. That was all. |
| 2 | A
Well, I mean, there's no names | 2 | Q
Well, didn't they ask you to send |
| 3 | printed. There's just a signature on it. | 3 | documents to them? |
| 4 | And, as I said, I believe I got this served | 4 | MR. BASSETT: Object to form. |
| 5 | by someone who came from New York City to | 5 | A
Yeah. Those documents were part |
| 6 | serve me with this. And it was like on a -- | 6 | of a document request, right? |
| 7 | it was maybe a week or two before the date | 7 | Q
I don't know. That's why I'm |
| 8 | by memory. | 8 | asking. |
| 9 | Q
Have you spoken with anyone other | 9 | A
Yeah. They were part of a |
| 10 | than Mr. Despins before traveling to New | 10 | document request that I got where they said |
| 11 | York City that day? | 11 | we need all communication, this, that and |
| 12 | A
No. I don't recall. | 12 | the other. And at some point I told them |
| 13 | Q
Is it therefore likely that the | 13 | that I had, you know, no emails because my |
| 14 | person you called at Paul Hastings while | 14 | email account had been deleted according to |
| 15 | traveling to New York City was Mr. Despins? | 15 | Coldwell Banker. And that I had supplied |
| 16 | MR. BASSETT: Object to form. | 16 | everything that I had. |
| 17 | A
Yes. It's possible. But I also | 17 | And at some point in time they |
| 18 | had communication from Avi and this other | 18 | said, well, don't you have anything like |
| 19 | person you referred to, Laff, Raft, or | 19 | texts, and I said, yes, but I don't know how |
| 20 | something like that. But, no, I was not -- | 20 | you can copy texts. And at some point I |
| 21 | I don't remember speaking to anyone. | 21 | figured out how to do that. And I believe |
| 22 | Q
What else did the person from Paul | 22 | it was on a computer, that you can copy and |
| 23 | Hastings tell you in addition to the fact | 23 | print texts. And I scanned those and sent |
| 24 | that you did not need to come to their | 24 | them as part of the documents that I had. |
| 25 | office that day? | 25 | Q
Do you recall when you provided |
| | Page 80 | | Page 81 |
| 1 | documents to Paul Hastings? | 1 | noticed there were a lot of other people |
| 2 | A
I believe it was after the first | 2 | mentioned, and I was mentioned on one of |
| 3 | subpoena. I don't even know -- there is | 3 | them, and that's all. |
| 4 | one -- so this is the -- you can see the | 4 | Q
Is there a date next to |
| 5 | size of this. This is the first thing that | 5 | Mr. Lindsay's signature? |
| 6 | I got in via FedEx. And it doesn't have a | 6 | A
I don't actually -- on that first |
| 7 | date on it. | 7 | document that you mentioned, there -- yeah. |
| 8 | Q
Can you -- I think if you flip | 8 | Dated March 24, 2023, Newhaven, Connecticut. |
| 9 | through, and the first time you get to a | 9 | Q
How soon after that, did you send |
| 10 | signature, whether that signature be an ink | 10 | documents to Paul Hastings? |
| 11 | signature or an electronic signature, | 11 | A
Honestly, it -- I don't remember |
| 12 | there's probably a date near it. | 12 | the exact dates, but I do remember first |
| 13 | A
I mean, I got this, my firm got | 13 | checking with my previous coworkers and |
| 14 | this, and we all responded. I spoke to the | 14 | bosses at Coldwell Banker, and, ultimately, |
| 15 | lawyer at Coldwell Banker, and he said, yes, | 15 | with the chief legal counsel. Specifically |
| 16 | we got the same and we supplied whatever | 16 | because a lot of the documents they |
| 17 | information we had or they requested. | 17 | requested I didn't have access to. I didn't |
| 18 | It's Luc Lapin, Chapter 11 | 18 | have emails. I just had a file. |
| 19 | Trustee, by S Patrick R Lindsay, of Neuberg | 19 | So I don't have a lot of documents |
| 20 | Pepe & Monteith, 196 Church Street, 13th | 20 | other than what you saw today, offer to |
| 21 | Floor, Newhaven, Connecticut. Counsel for | 21 | purchase, representation agreement, |
| 22 | the Chapter 11 Trustee. I mean, this is a | 22 | ultimately a contract. And that was it. So |
| 23 | very big document with a lot of questions. | 23 | I didn't have much to offer. And I was told |
| 24 | I did not read the whole thing. I did not | 24 | that Coldwell Banker would -- 'cause they |
| 25 | read -- I read a couple of pages where I | 25 | would have the exact same documents, had |
21 (Pages 78 to 81)
| | of 46 | | |
|--------|---------------------------------------------------------------------------------|--------|----------------------------------------------------|
| | Page 82 | | Page 83 |
| 1 | already submitted those documents. | 1 | have also been subpoenaed. But I don't even |
| 2 | Q
When you -- on the day you | 2 | remember the name of that broker. It was |
| 3 | traveled to New York City, by that date had | 3 | someone I didn't really know, but I didn't |
| 4 | you previously provided documents to Paul | 4 | discuss it. |
| 5 | Hastings? | 5 | Q
Was it Martha Jeffrey? |
| 6 | A
Yes. | 6 | A
Sounds familiar, but I can't |
| 7 | Q
How did you send the documents to | 7 | confirm, but sounds familiar. |
| 8 | Paul Hastings? | 8 | Q
And how did you come in contact |
| 9 | A
Electronically, via email, as | 9 | with the broker who asked you whether you |
| 10 | attachments, I believe. | 10 | had been subpoenaed? |
| 11 | Q
So you could determine the date on | 11 | A
I just went to an open house. She |
| 12 | which you sent those documents by looking at | 12 | had a listing and I was looking at the |
| 13 | your email, correct? | 13 | house. And she knew that -- what I found |
| 14 | A
Probably. | 14 | out after Miles had purchased the house, |
| 15 | Q
And I may ask you to do that | 15 | that even though I had an exclusive right to |
| 16 | during a break, just to check your sent | 16 | be his broker, he worked with many other |
| 17 | items to see when you sent those documents | 17 | brokers in Greenwich. And that's all I |
| 18 | to Paul Hastings. | 18 | knew. |
| 19 | Did you -- other than speaking | 19 | And I know of one other or two |
| 20 | with former colleagues at Coldwell Banker | 20 | other names that I heard, but I never |
| 21 | and with Paul Hastings, have you discussed | 21 | checked into it because I didn't care. I |
| 22 | the subpoenas you received with anyone else? | 22 | mean, it was not -- I never thought that I |
| 23 | A
No. There was some broker at one | 23 | would be the only person he would ever talk |
| 24 | point who said, have you been subpoenaed, | 24 | to. So it was irrelevant to me. |
| 25 | and I said, yes, because of -- she said, I | 25 | Q
You testified just now that you |
| | | | |
| | | | |
| | Page 84 | | Page 85 |
| | | | |
| 1 | had an exclusive with Miles. Do you have | 1 | Q
It's not anyone named Miles, |
| 2 | any document signed by this person named | 2 | right? |
| 3 | Miles where he agreed that you would be his | 3 | MR. BASSETT: Objection to |
| 4 | exclusive broker? | 4 | form. |
| 5 | A
No. In fact, they crossed that | 5 | A
Correct. |
| 6 | out. Even though it was not Miles who | 6 | Q
And did you participate as a |
| 7 | obviously signed this, it was Max Krasner | 7
8 | broker in any transaction that Hudson |
| 8
9 | who did. And it said Hudson Diamond. And | 9 | Diamond participated in? |
| 10 | that was the document I got to represent | 10 | A
No.
Q
Have you acted as a broker on any |
| 11 | Miles in the transaction that ultimately | 11 | transactions in which the buyer on the |
| 12 | took place a year later. | 12 | contract was named Miles? |
| 13 | Q
You say that you were representing | 13 | |
| 14 | Miles, but the exclusive right to represent | 14 | MR. BASSETT: Objection to
form. |
| 15 | buyer agreement, which I think is what
you're referring to; is that correct? | 15 | A
No. |
| 16 | A
Right. | 16 | Q
Are you aware of the person you |
| 17 | Q
And that was marked as Exhibit 2 | 17 | knew as Miles owning and having title to any |
| 18 | to your deposition today, correct? | 18 | property in Greenwich, Connecticut? |
| 19 | A
Right. | 19 | MR. BASSETT: Objection to |
| 20 | Q
And the buyer that's listed on | 20 | form. |
| 21 | that the document is Hudson Diamond, | 21 | A
No. Other than -- I mean, he was |
| 22 | correct? | 22 | the person who showed up. He was the person |
| 23 | MR. BASSETT: Objection to | 23 | who arranged the payment of the transfer of |
| 24 | form. | 24 | funds. He, through his assistant, |
| 25 | A
That's correct. | 25 | instructed me on -- on these matters. But, |
22 (Pages 82 to 85)
| | of 46 | | |
|----------|-----------------------------------------------------------------------------------|----------|-------------------------------------------------------------------------------------|
| | Page 86 | | Page 87 |
| | | | |
| 1
2 | no, I had no proof. As you earlier said, I | 1
2 | Q
And did your prior firm, Coldwell |
| 3 | never asked for his official identification.
Q
You said he arranged for the | 3 | Banker, do anything to diligence the source |
| 4 | | 4 | of the funds for its commission? |
| 5 | transfer of the funds. What did you do to | 5 | MR. MAJOR: Objection to form. |
| 6 | diligence the source of funds that were used | 6 | A
No. |
| 7 | to purchase the property at 373 Taconic Road
in Greenwich, Connecticut? | 7 | Q
Did you do anything to diligence
the source of the funds for the commission |
| 8 | MR. BASSETT: Objection. | 8 | that was paid to your prior firm? |
| 9 | Form. | 9 | A
Just to clarify. |
| 10 | A
That was not my function. Once we | 10 | Commission is paid by the seller's |
| 11 | have an accepted offer, all details are | 11 | attorney. So the commission itself did not |
| 12 | negotiated and discussed between the two | 12 | come from the buyer. |
| 13 | lawyers. The selling or seller's attorney | 13 | Q
Well, is -- the seller's attorney |
| 14 | and the buyer's attorney. And so I was left | 14 | is not sending you its own funds, right |
| 15 | out of any discussion as to where the funds | 15 | they're sending funds from the sale? |
| 16 | were coming from and how and all that stuff. | 16 | MR. BASSETT: Objection to |
| 17 | Q
Your prior firm received a | 17 | form. |
| 18 | commission in connection with the purchase | 18 | A
Yes. |
| 19 | of the 373 Taconic Road in the Greenwich, | 19 | Q
So my question is: Did you or |
| 20 | Connecticut, right? | 20 | your prior firm do anything to diligence the |
| 21 | A
Right. | 21 | source of the purchase proceeds for 373 |
| 22 | Q
And from that commission that your | 22 | Taconic Road in Greenwich, Connecticut? |
| 23 | prior firm received, you received a share of | 23 | A
No. |
| 24 | that, right? | 24 | Q
No? You have no knowledge of who |
| 25 | A
Right. | 25 | provided the money to purchase that the |
| | | | |
| | | | |
| | Page 88 | | Page 89 |
| 1 | | 1 | |
| 2 | property, correct? | 2 | of this -- of my questioning; I want to |
| 3 | MR. BASSETT: Objection to | 3 | avoid you speculating. So when you say as |
| 4 | form.
A
No. | 4 | far as you were concerned it was Miles, that |
| 5 | Q
I just want to make sure the | 5 | was your assumption, right?
A
Correct. |
| 6 | record is clear. | 6 | MR. BASSETT: Objection -- |
| 7 | You're agreeing that you have no | 7 | object to the form. |
| 8 | knowledge about the source of funds used to | 8 | Q
In other words, you don't know |
| 9 | purchase 373 Taconic Road in Greenwich, | 9 | what bank account sent money to the seller's |
| 10 | Connecticut? | 10 | lawyer at the closing? |
| 11 | MR. BASSETT: Same objections. | 11 | MR. BASSETT: Same objection. |
| 12 | A
No. The only evidence I would | 12 | A
No. |
| 13 | have for that is that I arranged for the | 13 | Q
And you don't know the identity of |
| 14 | funds to be there through Max and the | 14 | the account holder that sent money to the |
| 15 | lawyer. And Max and the lawyer arranged for | 15 | seller's lawyer? |
| 16 | the funds to purchase the home. And those | 16 | MR. BASSETT: Same objection. |
| 17 | funds came through on time, but I had no | 17 | A
No. |
| 18 | responsibilities to where those funds came | 18 | Q
You don't know if it was an |
| 19 | from and I had no knowledge either. | 19 | individual or an entity, right? |
| 20 | Q
You had no knowledge of where the | 20 | MR. BASSETT: Same objection. |
| 21 | funds came from? | 21 | A
I did not. Perhaps the attorney |
| 22 | A
No. I mean, they came from the | 22 | would have known that. |
| 23 | buyer and that's, you know, as far as I was | 23 | Q
We're just -- this is your |
| 24
25 | concerned it was Miles.
Q
Mr. de Neree, as I said at the top | 24
25 | deposition, Mr. de Neree. I just want to
know what you know. |
23 (Pages 86 to 89)
| | of 46 | | |
|----------|-------------------------------------------------------------------------|----------|------------------------------------------------------|
| | Page 90 | | Page 91 |
| 1 | You don't know whether the -- | 1 | Q
Do you know how old Mr. Krasner |
| 2 | A
No. | 2 | is? |
| 3 | Q
-- holder of the account that sent | 3 | A
I have no idea. As I said, I have |
| 4 | the purchase proceeds to the seller's lawyer | 4 | not met him. So, I would imagine that |
| 5 | was an individual or an entity? | 5 | he's -- he had -- |
| 6 | MR. BASSETT: Objection to | 6 | Q
Well, don't imagine. I just want |
| 7 | form. | 7 | to know if you know how old he is? |
| 8 | A
I don't know. | 8 | A
No. I don't. |
| 9 | Q
And if it was an entity that owned | 9 | Q
When was last time you spoke with |
| 10 | the account that sent the purchase proceeds | 10 | Mr. Krasner? |
| 11 | to the seller's lawyer, you don't know who | 11 | A
I think it's around the time that |
| 12 | owns that entity? | 12 | the texts end. Let me look that the date. |
| 13 | MR. BASSETT: Same objection. | 13 | August 23, I would imagine that |
| 14 | A
No. | 14 | was a year ago. A year ago last |
| 15 | Q
Did Mr. Krasner attend any of the | 15 | communication with him. |
| 16 | showings that you arranged? | 16 | Q
Okay. You were shown some text |
| 17 | A
No. | 17 | messages earlier during the deposition by |
| 18 | Q
Did you ever meet Mr. Krasner in | 18 | Mr. Bassett. And on at least one occasion, |
| 19 | person? | 19 | perhaps more, you arranged for meetings |
| 20 | A
No. | 20 | at -- at a property in Greenwich, |
| 21 | Q
Did you do any diligence to | 21 | Connecticut by texting with Mr. Krasner; is |
| 22 | determine if the person you were speaking to | 22 | that correct? |
| 23 | was really Mr. Krasner? | 23 | A
That's correct. |
| 24 | MR. BASSETT: Objection. | 24 | Q
And you never texted with Miles, |
| 25 | A
No diligence, no. | 25 | right? |
| | | | |
| | | | |
| | Page 92 | | Page 93 |
| | | | |
| 1 | A
That's correct. | 1 | or wire transfer? |
| 2 | Q
You testified in response to one | 2 | MR. BASSETT: Objection as to |
| 3 | of my questions a little while ago, that at | 3 | form. |
| 4 | 373 Taconic Road in the Greenwich, | 4 | A
Do not recall. He was paid one |
| 5 | Connecticut you met Miles' wife and his son | 5 | way or the other via Max. Because Max was |
| 6 | and his daughter, correct? | 6 | instructed -- you know, I gave Max the |
| 7 | A
Correct. | 7 | contact information and so on and so forth. |
| 8 | Q
I assume that meeting at Taconic | 8 | Q
Was the inspector paid in cash? |
| 9 | Road was something you arranged through | 9 | A
I do not -- |
| 10 | Mr. Krasner? | 10 | MR. BASSETT: Form. |
| 11 | A
Yes. | 11 | A
-- know. |
| 12 | Q
And having arranged it through | 12 | Q
Did you see Miles hand the |
| 13 | Mr. Krasner, Miles' wife and his son and his | 13 | inspector cash? |
| 14 | daughter appeared at the property? | 14 | A
No. |
| 15 | A
Yes. | 15 | MR. BASSETT: Objection to |
| 16 | Q
You testified earlier in a | 16 | form. |
| 17 | response to a question by Mr. Bassett that | 17 | Q
Did can you see Miles hand the |
| 18 | Miles paid directly for the inspection, was | 18 | inspector a check? |
| 19 | that at 373 Taconic Road in Greenwich | 19 | A
No. |
| 20 | Connecticut? | 20 | Q
Did you witness Miles executing a |
| 21 | A
Yes. | 21 | wire transfer to the inspector? |
| 22 | Q
Do you recall who performed the | 22 | MR. BASSETT: Objection. |
| 23 | inspection? | 23 | A
No. |
| 24
25 | A
An independent inspector.
Q
Was that inspector paid by check | 24
25 | Q
Do you know how much the inspector
was paid? |
24 (Pages 90 to 93)
Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 26
| | of 46 | | |
|--------|-------------------------------------------------------------------------------|--------|---------------------------------------------|
| | Page 94 | | Page 95 |
| 1 | A
No, I don't recall. But the | 1 | it just said everything's fine. |
| 2 | amount would have been under a thousand -- | 2 | Q
Do you know the source of the |
| 3 | somewhere around \$1,200, maybe for a house | 3 | funds that were for any payment to any |
| 4 | that big. | 4 | inspector regarding 373 Taconic Road in |
| 5 | Q
You're basing that on your | 5 | Greenwich, Connecticut? |
| 6 | experience in the real estate industry, | 6 | A
No. I do not. |
| 7 | correct? | 7 | Q
I'm going to ask you, sir, if you |
| 8 | A
Correct and having dealt with an | 8 | could look at Exhibit 3, which are the text |
| 9 | inspector before. | 9 | messages. |
| 10 | Q
Okay. But you're not specifically | 10 | A
Tab 3, yeah. Yeah. |
| 11 | recalling what the charge was for this | 11 | Q
And if you could look at the text |
| 12 | particular inspection at 373 Taconic Road in | 12 | message from January 22, 2019 at 3:38 p.m.? |
| 13 | the Greenwich, Connecticut, right? | 13 | A
What page are we on? January, |
| 14 | A
No. I did not receive a copy of | 14 | what did you say? |
| 15 | the report. I don't have a copy of the | 15 | Q
January 22, 2019. |
| 16 | report. It was paid by the buyers via Max | 16 | A
Okay. |
| 17 | Krasner. And there was also -- there was an | 17 | Q
And you looked at this with |
| 18 | inspection report of the building, there was | 18 | Mr. Bassett earlier. The next text jumps |
| 19 | an inspection separately done of the septic | 19 | more than a year ahead, to |
| 20 | system by Bond, he was paid, also, | 20 | February 11, 2020. Do you see that? |
| 21 | separately. And there must have been | 21 | A
Yeah. |
| 22 | something about the water, the well, that | 22 | Q
It says: |
| 23 | they inspected because I do have a copy of | 23 | "Also, if you think there are |
| 24 | that report. I don't know for what reason | 24 | other options that might interest Miles, |
| 25 | I've got it, but I found it in my file. And | 25 | please forward and we will review them." |
| | Page 96 | | Page 97 |
| | | | |
| 1 | Do you see that? | 1 | it. I'm just asking you that it's certainly |
| 2
3 | A
Yes. | 2 | a possibility that there's a missing text |
| 4 | Q
It looks to me that there must
have been a proceeding message, right? | 3
4 | messages or missing text messages in this |
| 5 | Because someone wouldn't write more than a | 5 | chain?
MR. BASSETT: Objection to |
| 6 | year later a sentence that starts "also," | 6 | form. Counsel, I'll remind you that |
| 7 | wouldn't there be some form of introduction | 7 | you took pains to ask him not to |
| 8 | to recognize the passage of more than a year | 8 | speculate. |
| 9 | between messages? | 9 | Q
You can answer the question, sir. |
| 10 | MR. BASSETT: Objection to | 10 | A
No. I -- I have no reason to |
| 11 | form. | 11 | assume that's possible. |
| 12 | A
Yes. Probably a telephone | 12 | Q
Well, the messages can be deleted |
| 13 | conversation. | 13 | on your -- on your -- either on your phone |
| 14 | Q
Probably? | 14 | or on your Mac, correct? |
| 15 | Do you remember a telephone | 15 | MR. BASSETT: Objection. This |
| 16 | conversation? | 16 | is getting ridiculous. |
| 17 | A
No. | 17 | A
I have not deleted any messages. |
| | | | |
25 (Pages 94 to 97)
Q You're phone is capable of deleting messages, correct?
MR. BASSETT: Objection. A Yes. But I -- I have had no reason to delete messages. I never delete messages. Messages are kept forever. Q Your Mac is capable of the deleting text messages, correct?
Q Is there a chance that there are messages that are missing from this text
MR. BASSETT: Objection to
Q I'm -- I'm not trying to assume
A No. There is no reason to assume
chain?
form.
that at all.
### Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 27
| | of 46 | | |
|--------|----------------------------------------------------------------------------------|--------|-------------------------------------------------------------------------------------|
| | Page 98 | | Page 99 |
| 1 | MR. BASSETT: Objection. | 1 | particular in Greenwich, but elsewhere, it's |
| 2 | A
I assume so. | 2 | not uncommon for residential properties to |
| 3 | Q
Do you know who owns Greenwich | 3 | be owned by limited liability companies, |
| 4 | Land, LLC? | 4 | right? |
| 5 | MR. BASSETT: Objection to | 5 | A
Correct. |
| 6 | form. | 6 | Q
Do you understand that a limited |
| 7 | A
Other than the lawyer who received | 7 | liability company is owned by its member or |
| 8 | the funds to buy the purchase in the name of | 8 | members? |
| 9 | Land, LLC, no. I -- I can only assume that | 9 | A
Yes. |
| 10 | the money came through and that the purchase | 10 | Q
So a member in an LLC is analogous |
| 11 | went through. That's it. I don't -- | 11 | to a stockholder of a corporation, right? |
| 12 | Q
So you don't know who owns | 12 | A
I guess. |
| 13 | Greenwich Land, LLC? | 13 | Q
Do you know the identity of any |
| 14 | A
No source of funds. No source of | 14 | member of Greenwich Land, LLC? |
| 15 | funds. Well, I know that Miles instructed | 15 | A
No. |
| 16 | the purchase and that's as far as I know. | 16 | Q
Around the time of the purchase, |
| 17 | Q
Okay. Let's -- let's talk about | 17 | did you do anything to determine who the |
| 18 | that. | 18 | member or members were of Greenwich Land, |
| 19 | When you say "Miles instructed the | 19 | LLC? |
| 20 | purchase," were you privy to conversation | 20 | A
No. |
| 21 | between Miles and any lawyer? | 21 | Q
Do you know whether Miles' wife -- |
| 22 | MR. BASSETT: Objection to | 22 | withdrawn. |
| 23 | form. | 23 | Do you know what language or |
| 24 | A
No. | 24 | languages Miles' wife speaks? |
| 25 | Q
You testified that you -- that | 25 | MR. BASSETT: Object to form. |
| | | | |
| | Page 100 | | Page 101 |
| | | | |
| | | | |
| 1 | A
I do not. Chinese. I don't even | 1 | from 1:00 PM to 1:19 PM.) |
| 2 | know, Mandarin or Cantonese. Chinese, | 2 | VIDEOGRAPHER: We are now back |
| 3 | that's all I know. Very limited English. | 3 | on the record. The time is 1:19. |
| 4 | Q
Mr. de Neree, did you in your | 4 | Q
Mr. de Neree, do you understand |
| 5 | capacity as broker receive a copy of the | 5
6 | that you're still under oath? |
| 6 | purchase contract for 373 Taconic Road in | 7 | A
Yes. |
| 7 | Greenwich, Connecticut? | 8 | Q
Have you ever represented a |
| 8
9 | A
Yes. | 9 | partner of Paul Hastings in connection with
a potential real estate transaction? |
| 10 | Q
And who was the buyer under that | 10 | A
Yes, I have. Tom Kruger, a partner |
| 11 | contract? | 11 | at the time is a friend and client. |
| 12 | A
Greenwich Land, LLC.
Q
Did you ever see any contract for | 12 | Q
And I take it Mr. Kruger has |
| 13 | | 13 | referred other potential clients to you? |
| 14 | 373 Taconic Road in the Greenwich,
Connecticut with a different buyer listed? | 14 | MR. BASSETT: Objection to |
| 15 | A
No. | 15 | form. |
| 16 | MR. MAJOR: I don't have too | 16 | A
I don't remember who specifically, |
| 17 | | 17 | but yes he has definitely promoted me and |
| 18 | much more. Why don't we take a
10-minute break, Mr. de Neree, if | 18 | helped me get other listings or buyers. |
| 19 | that's okay with you, and then we'll | 19 | Q
Do you ever work on any |
| 20 | | 20 | transactions for his brother, Chip? |
| 21 | come back on the record.
THE WITNESS: Yeah. | 21 | MR. BASSETT: Object to form. |
| 22 | | 22 | A
Yes. I have. |
| 23 | VIDEOGRAPHER: We are now
going off the record. The time is | 23 | Q
And did you get further referrals |
| 24 | 1:00 p.m. | 24 | from Chip Kruger? |
| 25 | (Whereupon, a recess was taken | 25 | A
Not that I can remember |
26 (Pages 98 to 101)
| | of 46 | | |
|----------|-------------------------------------------------------|----------|--------------------------------------------------------------------------------------------|
| | Page 102 | | Page 103 |
| 1 | specifically, but it wouldn't surprise me if | 1 | house? |
| 2 | I got recommended by him to someone else | 2 | A
Yes. |
| 3 | whom with I subsequently had some business. | 3 | Q
Did you observe the son or the |
| 4 | Q
I want to ask you some questions, | 4 | daughter communicating with Miles's wife? |
| 5 | Mr. de Neree, about the time you were at 373 | 5 | A
I'm sure -- no, I don't remember |
| 6 | Taconic Road property when Miles' wife, son | 6 | specifically, I don't have any specific |
| 7 | and daughter were there. The first question | 7 | recollection of that. |
| 8 | is, I assume you greeted Miles's wife in | 8 | Q
Did you walk around the house with |
| 9 | some fashion notwithstanding the language | 9 | Mile's wife, son and daughter? |
| 10 | barrier? | 10 | A
Yes. |
| 11 | A
Yep. | 11 | Q
Did you witness any conversation |
| 12 | Q
Did you speak with Miles' son? | 12 | taking place in a Chinese language whether |
| 13 | A
I don't remember a conversation | 13 | that be Mandarin or Cantonese? |
| 14 | with his son. I do remember a conversation | 14 | A
Yes. |
| 15 | with his daughter. She told me she was a | 15 | Q
But you don't understand what was |
| 16 | film student in New York and it happened to | 16 | being said, right? |
| 17 | be that my son was a film student not in New | 17 | A
Correct. |
| 18 | York, but there was some commonalities so we | 18 | Q
Was there anyone there translating |
| 19 | talked about the film business and the film | 19 | for you? |
| 20 | study that she was going through. | 20 | A
No. |
| 21 | Q
Did they look at the house? | 21 | Q
The conversation that was taken |
| 22 | A
Yes. | 22 | place in a Chinese language, whether that be |
| 23 | Q
Did they go inside the house? | 23 | Mandarin or Cantonese, that was a |
| 24 | A
Yes. | 24 | conversation among Miles' wife, son and |
| 25 | Q
Did they walk around inside the | 25 | daughter, right? |
| | | | |
| | | | |
| | Page 104 | | Page 105 |
| | | | |
| 1 | MR. BASSETT: Object to form. | 1 | MR. BASSETT: |
| 2 | A
Correct. You mentioned all four, | 2 | A
Okay. |
| 3 | right, Miles, his wife, and his son, and his | 3 | Q
So if I could have, we'll start by |
| 4 | daughter, they spoke amongst themselves in | 4 | having my colleague please put another |
| 5 | Chinese at times. | 5 | exhibit, which is a picture, into the chat. |
| 6 | Q
While they were walking around the | 6 | And this will be marked as de Neree |
| 7 | interior of the house? | 7 | Exhibit 7, I believe. |
| 8 | A
Correct. | 8 | (Whereupon, Picture of Miles Guo |
| 9 | Q
And perhaps also on the grounds of | 9 | was marked as Exhibit 7 for |
| 10 | the property? | 10 | identification as of this date.) |
| 11 | A
Yes. | 11 | A
Yes. I have it. |
| 12 | Q
Can I just have a moment please, | 12 | Q
Mr. de Neree, do you recognize the |
| 13 | sir. Mr. de Neree, the meeting at 373 | 13 | person in this picture? |
| 14 | Taconic Road in Greenwich, Connecticut that | 14 | MR. MAJOR: Objection to form. |
| 15 | was attended by Miles's wife, the son and | 15 | A
Miles. |
| 16 | daughter, did that happen before closing of | 16 | Q
This is the person that you've |
| 17 | the purchase of 373 Taconic Road? | 17 | been referring to throughout your testimony |
| 18 | A
Yes. | 18 | as Miles? |
| 19 | MR. MAJOR: Thank you very | 19 | A
Yes. |
| 20 | much for your time, Mr. de Neree. | 20 | Q
And you know that from having met |
| 21 | We have no further questions at this | 21 | him on multiple occasions? |
| 22 | time. | 22 | A
Correct. |
| 23 | MR. BASSETT: I do have a few | 23 | Q
You testified again, during your |
| 24
25 | additional questions, Mr. de Neree.
EXAMINATION BY | 24
25 | examination by Mr. Major about Mr. Krasner,
and I believe what you told me this morning |
27 (Pages 102 to 105)
| | of 46 | | |
|----|----------------------------------------------|----|----------------------------------------------|
| | Page 106 | | Page 107 |
| 1 | is, the individual you've been referring to | 1 | Mr. Krasner about arranging times to see the |
| 2 | as Mr. Krasner contacted you about helping | 2 | property; do you remember that? |
| 3 | Miles find a property to buy, correct? | 3 | A
Correct. |
| 4 | MR. MAJOR: Objection to form. | 4 | Q
And Mr. Krasner told you that |
| 5 | A
That's correct. | 5 | people would show up a certain time, |
| 6 | Q
And based on your interactions | 6 | correct? |
| 7 | that you describe that you had with Miles, | 7 | A
That's correct. |
| 8 | do you have any reason to believe that the | 8 | Q
And one of the persons who showed |
| 9 | person that you've been describing as | 9 | up was Miles? |
| 10 | Mr. Krasner did not have authority to act on | 10 | A
Yes. |
| 11 | behalf of Miles? | 11 | Q
There's been some testimony about |
| 12 | MR. MAJOR: Objection to form. | 12 | Mile's wife, do you know her name? |
| 13 | A
No. | 13 | A
No. I don't. |
| 14 | Q
In fact, during your discussions | 14 | Q
This meeting, and to be clear, |
| 15 | that you had with Miles in person, he told | 15 | this meeting that you were describing where |
| 16 | you to work with this person you've been | 16 | the wife, the son and daughter were present, |
| 17 | referring to as Mr. Krasner to help complete | 17 | was Miles also there? |
| 18 | the purchase of the property at Taconic | 18 | A
Yes. |
| 19 | Road, right? | 19 | Q
You testified that you don't know |
| 20 | MR. BASSETT: Objection to | 20 | who the members who own -- member or |
| 21 | form. | 21 | members, who own Greenwich Land, LLC., are, |
| 22 | A
That's correct. | 22 | do you remember that? |
| 23 | Q
And there were some text messages | 23 | A
That's correct. |
| 24 | we looked at when you wear talking about | 24 | Q
But based on all of your |
| 25 | showing properties and you were texting with | 25 | interactions with Miles and Mr. Krasner that |
| | | | |
| | Page 108 | | Page 109 |
| 1 | you discussed, it was your understanding | | |
| | | 1 | A
No. |
| 2 | that Miles ultimately was the one who was | 2 | Q
You were asked some questions |
| 3 | making the decision as to buy the Taconic | 3 | about business relationship properties you |
| 4 | Road property, right? | 4 | had sold for Mr. Tom Kruger, a partner at |
| 5 | MR. MAJOR: Objection to form. | 5 | Paul Hastings; do you remember that? |
| 6 | A
That's correct. | 6 | A
Yes. |
| 7 | Q
You also testified that people | 7 | Q
Do you know whether he is still a |
| 8 | use, in your experience as a realtor, LLCs | 8 | partner at Paul Hastings? |
| 9 | to complete their property purchases? | 9 | A
No. He retired in January of this |
| 10 | A
That's correct. | 10 | year. |
| 11 | Q
And that is what you understood | 11 | Q
Okay. And have you spoken to |
| 12 | was happening here with respect to Greenwich | 12 | Mr. Kruger about any of the substance |
| 13 | Land and Miles, correct? | 13 | related to this case at all? |
| 14 | A
That's correct. | 14 | A
I did have a conversation with him |
| 15 | MR. MAJOR: Objection to form. | 15 | mentioning that I had been subpoenaed. And |
| 16 | Q
In all of your interactions with | 16 | he said, you know, you better check with |
| 17 | Miles and Mr. Krasner, did you ever come to | 17 | your legal department at Coldwell Banker, |
| 18 | have an understanding that anyone other than | 18 | make sure that you're properly represented |
| 19 | Miles was making the decisions with respect | 19 | and so forth and so on, that's all I |
| 20 | to the purchase of a Taconic Road property? | 20 | remember him advising me. |
| 21 | A
No. | 21 | Q
Nothing about the substance of |
| 22 | MR. MAJOR: Objection to form. | 22 | this case, to your knowledge? |
| 23 | Q
Did Miles ever tell you that his | 23 | A
No. |
| 24 | wife was the one who was purchasing the | 24 | Q
Has your relationship with |
| 25 | Taconic Road property? | 25 | Mr. Kruger in any way impacted the |
28 (Pages 106 to 109)
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| | Page 110 | Page 111 | | | | | |
| 1 | truthfulness of your testimony here today? | 1 | | | | | |
| 2 | A
No. | 2
_______________________________ | | | | | |
| 3 | MR. BASSETT: One moment, | 3
EMILE DE NEREE | | | | | |
| 4 | please. | 4 | | | | | |
| 5 | No more questions. | 5 | | | | | |
| 6 | VIDEOGRAPHER: Okay. That | 6
Subscribed and sworn to | | | | | |
| 7 | concludes today's deposition. We | before me on this ____ day | | | | | |
| 8 | are going off the record at | 7
of ___________, __________.
8 | | | | | |
| 9 | 1:34 p.m. | 9
_______________________________ | | | | | |
| 10 | COURT REPORTER: Mr. Bassett, | Notary Public | | | | | |
| 11 | are you ordering a copy of the | 10 | | | | | |
| 12 | transcript? | 11 | | | | | |
| 13 | MR. BASSETT: Yes. | 12 | | | | | |
| 14 | COURT REPORTER: Do you want a | 13 | | | | | |
| 15 | rough? | 14 | | | | | |
| 16 | MR. BASSETT: What's the | 15
16 | | | | | |
| 17 | turnaround time on the final? | 17 | | | | | |
| 18 | COURT REPORTER: Eight to | 18 | | | | | |
| 19 | 10 days. | 19 | | | | | |
| 20 | MR. BASSETT: Yeah. We | 20 | | | | | |
| 21 | probably should have a rough, just | 21 | | | | | |
| 22 | in case. | 22 | | | | | |
| 23 | (Whereupon, this examination was | 23 | | | | | |
| 24 | concluded at 1:34 PM.) | 24 | | | | | |
| 25 | | 25 | | | | | |
| 1
2
3
4
5
6
7
8
9
10
11
12
13 | I N D E X
WITNESS: EMILE DE NEREE
EXAMINATION BY
PAGE
MR. BASSETT
6
MR. MAJOR
65
MR. BASSETT
104
E X H I B I T S
EXHIBIT
DESCRIPTION
PAGE
Exhibit 1
Emile de Neree's
10
Compass Transactions
Exhibit 2
Exclusive Right to
18
Represent Buyer
Agreement (GREE002323)
Exhibit 3
Text Messages
27 | 1
C E R T I F I C A T E
2
3
I, KIARA MILLER,
4
A Shorthand Reporter and Notary Public of the
5
State of New York, do hereby certify:
6
7
That the witness whose examination is
8
hereinbefore set forth, was duly sworn or
9
affirmed by me, and the foregoing transcript is
10
a true record of the testimony given by such
11
witness.
12
13
I further certify that I am not related to any
14
of the parties to this action by blood or | | | | | |
| 14 | | 15
marriage, and that I am in no way interested in | | | | | |
| 15 | Exhibit 4
Offer to Purchase Real 48 | 16
the outcome of this matter. | | | | | |
| 16 | Estate (GREE02327)
Exhibit 5
Email (WBAM_009051)
52 | 17 | | | | | |
| 17 | Exhibit 6
Residential Real Estate 55 | 18 | | | | | |
| | Sales Agreement | 19
_________________________ | | | | | |
| 18
19 | (GREE02328)
Exhibit 7
Picture of Miles Guo
105 | 20
KIARA MILLER | | | | | |
| 20 | | 21 | | | | | |
| 21 | | 22 | | | | | |
| 22
23 | | 23 | | | | | |
| | | 24 | | | | | |
| | | | | | | | |
| 24
25 | | 25 | | | | | |
29 (Pages 110 to 113)
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| | Page 114 | |
| 1
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7
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9
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14
15 | E R R A T A S H E E T
NAME OF CASE: KWOK v. GREENWICH LAND
DATE OF DEPOSITION: August 24, 2023
NAME OF WITNESS: EMILE DE NEREE
Reason codes:
1. To clarify the record.
2. To conform to the facts.
3. To correct transcription errors.
Page ____ Line ____ Reason____
From ___________________ to_________________
Page ____ Line ____ Reason____
From ___________________ to_________________
Page ____ Line ____ Reason____
From ___________________ to_________________
Page ____ Line ____ Reason____
From ___________________ to_________________ | |
| 16
17 | Page ____ Line ____ Reason____
From ___________________ to_________________ | |
| 18
19 | Page ____ Line ____ Reason____
From ___________________ to_________________ | |
| 20
21
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23
24 | Page ____ Line ____ Reason____
From ___________________ to_________________
_______________________ | |
| 25 | EMILE DE NEREE | |
| | | |
| | | |
| Page 115 | |
|----------|--|
| | |
| A | affirmed
113:9 | appointments | attended
104:15 | 2:1 4:10 67:3,6 |
|----------------------------|--------------------------|------------------------|---------------------------|----------------------------|
| a.m
2:19 4:4 | afternoon
65:23 | 32:20 | attending
4:14 | 67:10,16 70:10 |
| 76:8 | against-
1:11 | appreciate
6:10 | attention
43:22 | 70:16 74:10 |
| able
15:18 42:19 | 2:11 | approached | 55:2 | barrier
102:10 |
| 30:12
absolutely | 59:20
agenda | 26:22 45:5 | 4:21
attorney | 6:23
based |
| 53:10 | 60:10 | 70:13 | 86:13,14 87:11 | 38:21 42:20 |
| accepted
15:23 | agent
38:14,17 | appropriate | 87:13 89:21 | 51:2 106:6 |
| 46:7 86:11 | 59:23 | 9:19 | August
1:19 | 107:24 |
| access
7:23 | ago
9:2,8 91:14 | approximate | 2:19 4:3 30:21 | basically
9:18 |
| 31:19 33:5,10 | 91:14 92:3 | 32:8,14 | 31:9,14 53:5 | 19:14 44:15 |
| 81:17 | 23:13
agreed | approximately | 53:10,22 71:4 | 94:5
basing |
| account
15:14 | 84:3 | 14:22 44:24 | 91:13 114:4 | Bassett
3:7 4:22 |
| 33:9 79:14 | agreeing
88:7 | architect
57:18 | Austin
3:14 5:10 | 4:23 6:4,6 18:4 |
| 89:9,14 90:3 | agreement
16:4 | architects
58:2 | authority | 27:21 30:7 |
| 90:10 | 18:2,9,18,19 | 58:12,20 | 106:10 | 48:1,20 51:23 |
| 54:1
accounts | 18:23 20:21 | 85:23
arranged | 14:17
available | 52:4 55:21 |
| 11:8
accurate | 22:13 26:4,17 | 86:3 88:13,15 | 17:9 45:8 | 64:24 65:13 |
| 28:20 54:11 | 55:16 56:5
57:6 81:21 | 90:16 91:19
92:9,12 | 64:15
Avenue
3:4,10 | 66:8,25 70:4
72:21 74:6 |
| acknowledged | 84:14 112:12 | arranging
107:1 | 6:1 | 76:13 78:1,16 |
| 46:9 | 112:17 | 16:25
asked | 73:19,20
Avi | 79:4 84:23 |
| acquire
21:9 | 20:18
agrees | 20:8 38:15 | 77:9 78:18 | 85:3,13,19 |
| 22:3 63:18 | ahead
13:9 | 43:7 83:9 86:2 | avoid
89:2 | 86:8 87:16 |
| 64:4 | 95:19 | 109:2 | aware
13:8 31:1 | 88:2,11 89:6 |
| acres
64:11 | al
1:5 2:5 | asking
31:24 | 31:14 33:12 | 89:11,16,20 |
| act
106:10 | alert
32:19 | 34:25 42:11 | 59:6 85:16 | 90:6,13,24 |
| acted
85:10 | 28:25
aligned | 53:16,25 79:8 | | 91:18 92:17 |
| 32:5 35:4
acting | 29:1 | 97:1 | B | 93:2,10,15,22 |
| 113:14
action
16:7 | allow
29:25 | asks
65:19 | 112:8
B | 95:18 96:10,21 |
| actions
actual
20:15 | allows
34:20 | aspect
59:3 | back
8:1 9:25 | 97:5,15,20 |
| added
20:8,10 | ambiguity
24:9 | assistant
14:12 | 20:23 23:8 | 98:1,5,22 |
| 20:19 | 94:2
amount | 55:1 85:24 | 33:25 34:9 | 99:25 101:14 |
| addendum | 99:10
analogous | 11:1
assortment | 45:11 48:10 | 101:21 104:1 |
| 19:16,18 | answer
6:24 | assume
10:3 | 55:3 56:14,16 | 104:23 105:1 |
| addition
78:23 | 7:12,17 14:1 | 43:7 66:19 | 65:4,11 72:2 | 106:20 110:3 |
| additional
16:11 | 30:1 38:16,17 | 92:8 96:23,25 | 77:4 100:20 | 110:10,13,16 |
| 20:16 48:13 | 51:10 66:8 | 97:11 98:2,9 | 101:2 | 110:20 112:4,6 |
| 104:24 | 97:9 | 102:8 | background | 18:14
Bates |
| address
5:21 | apologies
75:19 | assumption | 11:16 | 48:24 52:15 |
| 20:15 27:6 | apologize
55:10 | 21:13 89:4 | 89:9
bank | 55:25 |
| ADK@MSF- | appear
71:18 | attached
19:20 | Banker
9:1,1 | beautiful
64:10 |
| 3:12 | 72:11,13 | attachment | 20:17 24:13,19 | began
16:19 |
| 1:13
Adv | 92:14
appeared | 34:21 | 33:8,12,20 | 4:20
beginning |
| 5:1,9
adversary | Apple
28:21 | attachments | 79:15 80:15 | 9:6 58:7 |
| 66:1 | apply
66:6 | 82:10 | 81:14,24 82:20 | behalf
2:17 3:3 |
| advising
109:20 | appointment | attempt
69:5 | 87:2 109:17 | 3:9 4:24 6:21 |
| | 61:19 | attend
90:15 | bankruptcy
1:1 | 32:5 35:4 |
| | | | | Page 116 |
|---------------------------------------|-------------------------------|------------------------------|-------------------------------------|---------------------------|
| | | | | |
| 76:11 77:24 | 85:7,10 100:5 | 76:3 | 82:16
check | 9:1 20:17 |
| 106:11 | 83:17
brokers | 100:2
Cantonese | 92:25 93:18 | 24:13,19 33:8 |
| believe
8:21 | brother
101:20 | 103:13,23 | 109:16 | 33:11,19 79:15 |
| 10:21 12:5 | budget
9:20 | capable
97:18 | checked
83:21 | 80:15 81:14,24 |
| 14:22,25 26:1 | building
59:15 | 97:24 | checking
81:13 | 82:20 87:1 |
| 26:21 42:6,8 | 94:18 | capacity
100:5 | Chi
1:13 2:13 | 109:17 |
| 42:12 59:11 | 11:24
bunch | 22:14
caps | 4:8 5:7 66:2 | 5:3
colleague |
| 60:10 67:18 | 17:7 | care
83:21 | chief
81:15 | 10:7 17:23 |
| 69:22 71:15 | Burke
53:3 | Carstensen
3:19 | children
69:12 | 27:14 48:14 |
| 73:15 74:20,23 | business
70:19 | 4:15 | 69:15 | 55:13 105:4 |
| 76:3 78:4 | 102:3,19 109:3 | case
1:7 2:7 6:15 | Chinese
100:1,2 | colleagues
51:24 |
| 79:21 80:2 | 12:6 50:11
buy | 12:24 13:4 | 103:12,22 | 82:20 |
| 82:10 105:7,25 | 50:22 51:12 | 23:18,20 28:8 | 104:5 | combination |
| 106:8 | 64:20 98:8 | 28:14 30:9 | Chip
101:20,24 | 12:3,6 |
| best
7:3 31:12 | 106:3 108:3 | 36:13 38:14 | Chris
5:6 65:24 | come
16:23 |
| 42:1 45:23 | buyer
9:14,21 | 47:12 57:17 | CHRISTOPH | 34:18 38:22 |
| 75:24 | 10:4 15:22 | 66:10,24 70:17 | 3:13 | 47:4 54:20 |
| 109:16
better
big
17:4 80:23 | 18:2,9,18,20
19:1 20:17,18 | 72:20 73:6
74:5 109:13,22 | 80:20
Church
city
71:20,21 | 63:22 70:18
78:24 83:8 |
| 94:4 | 24:19 25:17,24 | 110:22 114:3 | 75:5,9,15 | 87:12 100:20 |
| bit
14:24 22:9 | 50:3,7,17 | cash
93:8,13 | 77:15,20 78:5 | 108:17 |
| 27:12 31:23 | 51:16 84:14,20 | cause
19:14 | 78:11,15 82:3 | comfortable
7:9 |
| 113:14
blood | 85:11 87:12 | 81:24 | CJM@MSF- | 86:16
coming |
| 45:4
blue | 88:23 100:9,14 | 36:12
cell | 3:12 | commencing |
| boat
17:4 | 112:12 | Central
77:3 | clarification | 2:19 |
| Bond
94:20 | buyer's
22:13 | certain
53:16 | 15:13 59:21 | comments
38:4 |
| bone
36:20 | 23:25 24:18,21 | 107:5 | clarify
7:3 87:9 | commission |
| bosses
81:14 | 25:4 86:14 | certainly
97:1 | 114:7 | 23:21 86:18,22 |
| 18:14
bottom | 9:11
buyers | 113:5,13
certify | 31:8,12
clear | 87:3,7,10,11 |
| 22:11,12,20 | 50:10 94:16 | cetera
42:5,5 | 45:4 47:17 | commonalities |
| 48:25 52:16 | 101:18 | 43:9 | 88:6 107:14 | 102:18 |
| 53:4 55:24 | buying
26:13 | chain
52:23 | client
17:1 | communicate |
| bought
12:1 | 42:17,23 45:3 | 96:20 97:4 | 101:11 | 27:2 |
| 53:24 54:6,16 | 51:2 61:22 | 96:18
chance | 34:22
clients | communicated |
| break
7:6,13 | | change
51:1,7 | 101:13 | 26:24 |
| 48:3 49:11 | C | changed
58:24 | close
8:5 64:20 | communicating |
| 82:16 100:18 | 3:1 113:1,1
C | changes
57:20 | closed
47:18 | 103:4 |
| breaks
7:9 | calender
60:2,3 | 59:3 | closer
46:4 | communication |
| 1:3
Bridgepoint | 60:11 | 1:6,9
Chapter | 15:25
closing | 8:7 14:25 27:6 |
| 2:3 4:11 | call
20:20 24:12 | 2:6,9 3:3 4:7 | 42:21,21 47:14 | 27:7 33:2 |
| Bridgeport | 57:1 71:6 | 4:24 6:7 12:24 | 53:7 56:11,12 | 44:22 63:1 |
| 71:19 72:13 | 16:25
called | 13:4 66:9 | 57:7 59:22 | 71:15 72:8 |
| 73:10,24 74:24 | 18:1 66:16 | 80:18,22 | 67:2 89:10 | 73:21 78:18 |
| broader
8:16 | 71:9 74:3 | charge
70:16 | 104:16 | 79:11 91:15 |
| 8:11
broker | 75:15 78:14 | 94:11 | 20:14
Coast | communicatio |
| 82:23 83:2,9 | canceled
72:17 | chat
10:8 48:14 | codes
114:6 | 31:25 32:3 |
| 83:16 84:4 | 72:18 74:1 | 55:14 105:5 | Coldwell
8:25 | 44:16 73:19 |
| | | | | Page 117 |
|--------------------|--------------------|---------------------|---------------------|---------------------|
| | | | | |
| communicator | 114:7
conform | 99:11 | 32:21 | 27:23,24 29:24 |
| 46:21 | 1:2
Connecticut | 8:12
correct | 66:3
covering | 30:14 48:12,22 |
| community | 2:2 4:11 5:25 | 13:5 17:17,22 | coworkers
81:13 | 49:2 52:6,7,14 |
| 11:18,20 | 6:2 8:16,18 | 21:1,2 23:23 | crossed
20:1 | 52:19 55:22 |
| companies
19:6 | 17:15 20:14,16 | 24:4 25:21 | 23:10 84:5 | 56:3 60:1,8 |
| 21:15 99:3 | 74:20 80:21 | 28:22 29:8,12 | currently
34:5 | 65:13,23 88:25 |
| 21:21
company | 81:8 85:18 | 30:20 31:7,10 | 30:4
custom | 89:24 100:4,18 |
| 22:2 59:25 | 86:7,20 87:22 | 31:17,20,21 | | 101:4 102:5 |
| 60:5 99:7 | 88:10 91:21 | 34:7 35:20 | D | 104:13,20,24 |
| Compass
5:25 | 92:5,20 94:13 | 44:14,19 50:1 | D
112:1 | 105:6,12 111:3 |
| 8:24 9:3 10:18 | 95:5 100:7,14 | 50:5,25 51:5 | D-E
5:24 | 112:2,10 114:5 |
| 10:23 112:10 | 104:14 | 51:13 52:22 | date
4:2 10:20 | 114:25 |
| compensate | 25:2
connection | 53:9 56:9,24 | 16:5 18:12 | 42:19
deadlines |
| 20:4 | 86:18 101:8 | 57:7 58:1,4,15 | 27:20 32:9 | deal
13:24 49:20 |
| compensated | considerably | 58:16 73:12 | 37:18 41:22,24 | dealt
94:8 |
| 23:14,18 | 42:12 | 75:5,10 82:13 | 48:19 52:3 | Deane
3:19 4:15 |
| compensation | consistent
35:2 | 84:15,18,22,25 | 55:19 56:11,19 | Dear
53:23 |
| 20:2 22:10 | 29:17
consists | 85:5 88:1 89:5 | 75:14 78:7 | 12:23
debtor |
| 23:9,16 | contact
16:23 | 91:22,23 92:1 | 80:7,12 81:4 | 13:4 |
| complete
106:17 | 33:11 76:19 | 92:6,7 94:7,8 | 82:3,11 91:12 | Debtors
1:6 2:6 |
| 108:9 | 83:8 93:7 | 97:14,19,25 | 105:10 114:4 | decided
42:22 |
| complies
76:18 | contacted
67:18 | 99:5 103:17 | dated
18:23 | 46:5,11 75:14 |
| 8:4
computer | 76:21 106:2 | 104:2,8 105:22 | 30:21 36:2 | 10:4
decides |
| 28:14,17 79:22 | 15:24
contract | 106:3,5,22 | 43:24 49:24 | 38:24
decision |
| Conboy
52:24 | 49:22 56:6 | 107:3,6,7,23 | 53:4,22 55:8 | 39:5 46:24 |
| concern
26:10 | 81:22 85:12 | 108:6,10,13,14 | 56:7 81:8 | 50:22 51:12 |
| concerned
88:24 | 100:6,10,12 | 114:8 | dates
37:9 59:10 | 108:3 |
| 89:3 | conversation | corrected
36:20 | 81:12 | decision-maker |
| 25:4
concerning | 30:4 70:2,25 | 4:17
counsel | daughter
69:23 | 46:13,19 |
| 26:24 | 77:12 96:13,16 | 7:15 80:21 | 92:6,14 102:7 | decisions
108:19 |
| concluded | 98:20 102:13 | 81:15 97:6 | 102:15 103:4,9 | defendants
1:14 |
| 110:24 | 102:14 103:11 | couple
6:16 24:2 | 103:25 104:4 | 2:14,18 3:9 5:8 |
| concludes
110:7 | 103:21,24 | 24:15 41:11 | 104:16 107:16 | 6:21 66:1 |
| 4:13
conference | 109:14 | 48:13 60:21 | day
33:10 37:12 | 12:5
definitely |
| 4:18 | conversations | 80:25 | 37:21,24 42:9 | 36:15 101:17 |
| confidential | 38:19 | course
23:21 | 42:10,10 46:6 | delete
97:22,22 |
| 24:23 25:6 | cooperate
24:19 | court
1:1 2:1 | 52:11,11 60:6 | deleted
79:14 |
| confidentiality | copied
72:4 | 4:10 5:12,15 | 77:15,20 78:11 | 97:12,17 |
| 16:4 | 15:16
copy | 5:20 10:15 | 78:25 82:2 | 97:19
deleting |
| 39:17
confirm | 60:15 76:4 | 18:5 27:22 | 111:6 | 97:25 |
| 65:2 69:2 | 79:20,22 94:14 | 30:10 48:21 | 110:19
days | department |
| 75:15 83:7 | 94:15,23 100:5 | 52:5 110:10,14 | 1:17 2:17 4:5
de | 33:11 109:17 |
| confirmed
35:10 | 110:11 | 110:18 | 5:17,23 6:6,11 | depose
70:20 |
| 36:10 39:25 | corner
22:12,20 | courthouse | 7:21 8:10 10:9 | deposed
33:13 |
| 40:11 45:13 | 49:1 52:16 | 72:14,16 73:10 | 10:16,17,21 | 1:16
deposition |
| 47:10,11 | 55:24 | 73:24 | 12:22 15:7 | 2:17 4:5,12 |
| confirms
61:18 | corporation | covered
20:21 | 18:6 24:5 | 6:12 7:25 8:8 |
| 60:18 66:17 | 90:21,25 | driver
35:14 | English
38:20 | 18:1,8,17 |
|---------------------------------|-------------------------------|-------------------------|----------------------------|---------------------|
| 68:12 70:24 | direct
43:22 | 36:12 42:5 | 43:13,20 47:7 | 32:24 83:15 |
| 72:5 75:18 | 55:2 | driveway
47:16 | 100:3 | 84:1,4,13 |
| 76:25 84:18 | 9:23
direction | 5:17 113:8
duly | 26:16
enter | 112:11 |
| 89:24 91:17 | 40:22 | | entire
29:13 | execute
18:19 |
| 110:7 114:4 | directly
25:25 | E | entity
20:25 | executed
57:6 |
| describe
9:13 | 61:16 62:24 | E
3:1,1 112:1,8 | 26:18 51:3,19 | executing
93:20 |
| 11:9 13:15,18 | 66:20 92:18 | 113:1,1 114:2 | 89:19 90:5,9 | exhibit
10:16,19 |
| 14:5 37:22 | 83:4
discuss | 114:2,2 | 90:12 | 18:7,11 19:19 |
| 42:2 45:24 | discussed
41:3 | earlier
51:11 | entourage
42:4 | 20:10 27:19,23 |
| 58:10,18 106:7 | 44:4 82:21 | 68:11 86:1 | errors
114:8 | 28:1 32:25 |
| described
43:7 | 86:12 108:1 | 91:17 92:16 | escrow
53:17 | 34:1 48:18,22 |
| 44:4 64:16 | discussing
49:12 | 95:18 | 54:1 | 52:2,6,15 55:3 |
| 106:9
describing | 59:2
discussion | easier
51:10 | 3:7,13,14
ESQ | 55:18,23 56:3 |
| 107:15 | 86:15 | Eastern
4:4 | 41:7
essence | 56:14,15,15 |
| description
11:8 | discussions | Eight
110:18 | 42:25 43:2 | 60:22 84:17 |
| 112:9 | 106:14 | 28:14
either | essentially
53:15 | 95:8 105:5,7,9 |
| designer
57:18 | District
1:2 2:2 | 61:16 88:19 | estate
8:11,20 | 112:9,10,11,13 |
| designers
57:17 | 4:10 | 97:13 | 9:7,10 11:9 | 112:14,16,17 |
| 58:2,12,20 | 1:3 2:3
Division | electronic
80:11 | 15:25 21:25 | 112:19 |
| 1:9 2:9
Despins | 4:11 | Electronically | 46:8 48:17 | expenses
25:19 |
| 3:3 4:7,25 6:7 | docket
72:19,24 | 82:9
42:25 | 49:7,9 51:15 | 25:23 26:2 |
| 71:9 74:3 | 73:4 | eluded
3:6,12 | 55:16 94:6 | experience
17:3 |
| 77:16 78:10,15 | document
10:13 | email
7:23 8:1 15:14 | 101:9 112:15 | 22:1 94:6 |
| 27:13
detail | 10:16 15:10,12 | 15:18 27:4,5 | 112:17 | 108:8 |
| 31:23 | 15:25 18:6,14 | 31:25 32:3 | 1:5 2:5 42:5,5
et | 11:22
expertise |
| details
14:13 | 19:24 24:10,12 | 33:1,9 34:17 | 43:9 | explain
31:22 |
| 25:8 32:21 | 24:13 26:7 | 34:19 52:1,13 | evaluate
24:21 | 41:4 |
| 34:23 47:11 | 27:25 28:6,11 | 52:23 53:3,6 | everything's | explanation |
| 54:25 70:16 | 29:14 30:19,25 | 53:11,22 54:12 | 95:1 | 23:11 |
| 74:10,22 75:16 | 31:16 32:23 | 56:17,17 79:14 | 88:12
evidence | 61:16
expressed |
| 86:11 | 41:1 48:22,24 | 82:9,13 112:16 | exact
24:10,11 | extent
60:10,11 |
| determine
76:10 | 49:3 52:8,14 | emails
15:13,20 | 81:12,25 | F |
| 77:22 82:11 | 52:19 55:13 | 31:19 32:10,15 | exactly
33:6 | F
113:1 |
| 90:22 99:17
13:11
develop | 60:9 76:8 79:6
79:10 80:23 | 32:18 33:5,10 | 37:20 72:7
74:15 | fact
23:7 39:19 |
| 28:21
device | 81:7 84:2,9,21 | 71:16,24 79:13 | 6:3
examination | 51:2 57:9 |
| Diamond
19:2,3 | documents
15:7 | 81:18 | 65:21 104:25 | 66:17 78:23 |
| 19:15 20:23 | 15:15,21 16:1 | 1:17 2:17
Emile | 105:24 110:23 | 84:5 106:14 |
| 21:8,20 84:8 | 16:10,11,13,16 | 4:5 5:17,23 | 112:3 113:7 | facts
66:19 |
| 84:21 85:8 | 33:20,22 48:13 | 10:17 41:3 | 5:19 | 114:7 |
| 21:15
different | 72:10 73:5 | 111:3 112:2,10 | examined
8:4
example | familiar
10:23 |
| 41:23,25 | 74:8 79:3,5,24 | 114:5,25 | exception
27:7 | 12:22 83:6,7 |
| 100:14 | 80:1 81:10,16 | 17:10
ended | exchange
72:1 | 41:6
family |
| difficult
24:5 | 81:19,25 82:1 | engagement | exchanged | 42:14,18 |
| diligence
86:5 | 82:4,7,12,17 | 25:3,23 26:23 | 71:25 | far
30:19 88:23 |
| 87:2,6,20 | 15:17 60:6
doing | 26:25 | 15:22
exclusive | 89:3 98:16 |
| | | | | |
of 46
| farm
61:8 63:5 | 33:12 34:15 | 84:24 85:4,14 | G | 18:10,15 |
|---------------------------------|---------------------------------|--------------------------|---------------------|---------------------|
| 63:18 64:2,4,7 | 36:15 41:13 | 85:20 86:9 | gain
38:22 | 112:12 |
| 64:8 | 42:7 44:12 | 87:4,17 88:3 | gap
44:16 | GREE002327 |
| fashion
102:9 | 49:1 52:9,16 | 89:7 90:7 93:3 | gather
35:20 | 48:25 |
| 47:25
fast | 55:25 62:23 | 93:10,16 96:7 | 7:15
generally | GREE002328 |
| February
15:4 | 66:23 69:18 | 96:11,22 97:6 | 10:1 32:18,21 | 56:1 |
| 43:24 44:18 | 70:8,23 74:4 | 98:6,23 99:25 | 33:17 35:2 | GREE02327 |
| 45:18 49:24 | 74:23 80:2,5,9 | 101:15,21 | 46:22 47:23 | 48:17 112:15 |
| 55:8 56:8,12 | 81:6,12 102:7 | 104:1 105:14 | 49:20 53:18 | GREE02328 |
| 56:17 57:10 | 20:6,7 48:4
five | 106:4,12,21 | 58:10,18 | 55:17 112:18 |
| 59:6,18 95:20 | 64:25 | 108:5,15,22 | 97:16
getting | 1:12
Greenwich |
| FedEx
80:6 | flip
80:8 | formal
49:16 | give
9:23 14:15 | 2:12 4:8 5:8,25 |
| feedback
14:15 | Floor
3:10 80:21 | 56:5 | 18:4 38:17 | 6:1,1 11:21 |
| 38:6 | focus
8:15 11:21 | former
82:20 | 66:14 | 12:8 17:6,15 |
| Fein
3:10 5:6,11 | 54:8 | forth
37:10 58:8 | given
25:8 44:2 | 50:3,7,10,14 |
| 65:25 | 45:3
focused | 58:25 73:10 | 113:10 | 50:18 51:3,16 |
| figured
79:21 | focusing
33:25 | 75:17 76:23 | 41:14
gives | 51:19 52:9 |
| file
1:22 15:16 | followed
56:5 | 93:7 109:19 | giving
6:16 | 53:25 54:7,16 |
| 33:21 81:18 | following
41:8 | 113:8 | Gladys
63:4,9 | 66:2 83:17 |
| 94:25 | follows
5:19 | forward
36:17 | 63:10 | 85:18 86:7,19 |
| 4:9 73:5
filed | 14:11
followup | 44:8 74:1 | glasses
39:13 | 87:22 88:9 |
| 26:15
filled | 65:18 | 95:25 | 7:5 9:2,24,24
go | 91:20 92:4,19 |
| film
102:16,17 | footprint
8:16 | found
10:1 | 13:9 22:11 | 94:13 95:5 |
| 102:19,19 | foregoing
113:9 | 39:14 68:7,13 | 29:14 30:18 | 98:3,13 99:1 |
| final
110:17 | forever
97:23 | 83:13 94:25 | 38:2 40:25 | 99:14,18 100:7 |
| financial
24:23 | form
13:14,22 | four
20:7 104:2 | 53:21 55:6,12 | 100:11,13 |
| 25:6,13 | 14:7 17:16,21 | 47:15
Friday | 60:21 63:2 | 104:14 107:21 |
| find
9:24 17:14 | 21:12 22:5,7 | 61:7,20 | 72:16 75:16 | 108:12 114:3 |
| 17:19 21:5 | 23:3 26:19 | friend
101:11 | 76:22 102:23 | greeted
102:8 |
| 26:11 59:21 | 28:3 29:23 | front
11:7,15,22 | goes
7:19 39:12 | ground
66:6,11 |
| 63:5 76:22 | 32:6,17 33:7 | 17:3,4,9 70:2 | going
6:18 7:19 | grounds
104:9 |
| 106:3 | 35:5 38:1 39:1 | 77:23 | 8:1 16:9 21:8 | 11:12 21:6
guess |
| 60:8 70:21
fine | 39:6 40:6,14 | froze
33:9 | 21:16 23:1,10 | 22:10 64:7 |
| 95:1 | 40:18,23 43:3 | full
68:4,7 | 36:11 45:2 | 99:12 |
| finish
30:6,7 | 43:17 44:20,25 | function
34:19 | 48:2,6 54:24 | Guo
12:25 22:14 |
| 66:7 | 46:2,14,18 | 86:10 | 55:7 60:6 65:7 | 105:8 112:19 |
| 16:12
finished | 47:1,5,21 | 53:16
funds | 72:6 95:7 | 72:4
guys |
| 65:24 67:20
firm | 49:15,18 50:8 | 85:24 86:4,5 | 100:23 102:20 | H |
| 70:7 75:15 | 50:15,24 51:4 | 86:15 87:3,7 | 110:8 | 112:8 114:2
H |
| 80:13 86:17,23 | 51:8,21 53:19 | 87:14,15 88:8 | Gold
20:14 | half
9:2,8 14:9 |
| 87:1,8,20 | 54:13,18,22 | 88:14,16,17,18 | good
4:22 5:5 | hand
8:2 12:21 |
| first
5:17 6:13
6:14 11:4 | 57:13 58:13,22
59:9 61:14,24 | 88:21 95:3
98:8,14,15 | 64:6,11 65:23 | 93:12,17 |
| 14:25 15:1 | 62:5,9 64:5,23 | further
101:23 | government | handled
54:25 |
| 16:6,23 18:15 | 67:1 70:5 | 104:21 113:13 | 68:22 | 19:23
happen |
| 19:1 20:11 | 72:22 74:6 | future
70:21 | Grand
77:3 | 71:22 104:16 |
| 23:4 24:17 | 78:16 79:4 | | GREE002323 | happened
22:6,8 |
| | | | | |
| | | | | Page 120 |
|---------------------|--------------------|---------------------|---------------------|--------------------|
| | | | | |
| 36:9 71:21 | 8:15
homes | 31:16
included | 21:23
interest | 15:21
key |
| 102:16 | 11:15,18 | 24:22
including | 34:11 35:1 | 1:21 2:20
Kiara |
| happening | Honestly
71:5 | 25:5 70:11 | 44:7 61:16 | 5:13 113:3,20 |
| 75:20 108:12 | 81:11 | incurred
25:23 | 63:20 95:24 | Kim
3:14 5:10 |
| happy
7:2 | hope
74:16 | 26:2 | interested
14:19 | 26:19 |
| Harbor
63:6,19 | hoped
21:20 | independent | 17:1 26:12 | kind
6:16 7:18 |
| 15:16
hard | 21:23
hoping | 92:24 | 42:16 45:2 | 9:16 29:1 |
| Hastings
3:4 | 26:11 | Indian
63:5,19 | 61:22 113:15 | knew
23:4 68:24 |
| 4:24 5:4 67:17 | horse
61:8 | individual
22:2 | interior
57:18 | 83:13,18 85:17 |
| 67:19,20 70:8 | hour
48:2 | 37:10 89:19 | 104:7 | know
6:22 7:2,8 |
| 70:9 71:12,25 | house
45:3,6 | 90:5 106:1 | internet
68:17 | 10:10 13:1 |
| 73:14,22 76:9 | 57:10,21 59:1 | individuals | interpreter | 15:9 19:16,17 |
| 76:12,20 77:6 | 75:13 83:11,13 | 52:25 | 43:15 | 26:8 29:2,15 |
| 77:25 78:14,23 | 83:14 94:3 | industry
94:6 | introduced
58:8 | 30:2 33:16 |
| 80:1 81:10 | 102:21,23 | info
34:3 | 63:10 68:6 | 36:3,25 37:1 |
| 82:5,8,18,21 | 103:1,8 104:7 | information | 69:18 | 38:7,16 39:13 |
| 101:8 109:5,8 | houses
32:20 | 24:20,23 25:3 | introduction
6:5 | 47:24 62:17 |
| 39:14
he'll | 19:2,3
Hudson | 25:6,13 47:22 | 96:7 | 63:13 65:3 |
| head
75:14 | 19:15 20:23 | 61:18 64:13 | investment
64:7 | 66:20,20,23 |
| hear
13:22 34:9 | 21:8,20 84:8 | 80:17 93:7 | involved
67:11 | 67:12,21,24,25 |
| heard
52:9 | 84:21 85:7 | initials
22:14 | 67:13 74:9 | 68:1,1,3,7,9,10 |
| 68:21 70:23 | | ink
80:10 | involving
52:23 | 68:20 69:7,11 |
| 83:20 | I | 102:23,25
inside | 67:4,7,10,16 | 69:14 70:22 |
| 53:17
held | idea
17:4 21:16 | 94:23
inspected | 74:8 | 71:8 72:10,18 |
| help
106:17 | 91:3 | inspection
16:1 | irrelevant
83:24 | 73:1,16 74:17 |
| helped
101:18 | identification | 26:1 59:16 | island
20:14 | 75:1 76:7 79:7 |
| helping
64:20 | 10:19 18:11 | 92:18,23 94:12 | issue
8:1,6 | 79:13,19 80:3 |
| 106:2 | 27:20 48:19 | 94:18,19 | issued
68:23 | 83:3,19 88:23 |
| hereinbefore | 52:3 55:18 | 92:24
inspector | 82:17
items | 89:8,13,18,25 |
| 113:8 | 68:23 86:2 | 92:25 93:8,13 | | 89:25 90:1,8 |
| hereto
19:20 | 105:10 | 93:18,21,24 | J | 90:11 91:1,7,7 |
| hesitate
7:7 | identify
4:18 | 94:9 95:4 | J
3:13 | 93:6,11,24 |
| Hi
61:1,6 63:4 | 69:6 | inspectors
59:13 | JAM
1:7 2:7 | 94:24 95:2 |
| 57:19
high-end | identity
69:2 | 40:15
instructed | January
18:24 | 98:3,12,15,16 |
| higher
42:12 | 89:13 99:13 | 40:17 50:17 | 35:8,14 36:3,5 | 99:13,21,23 |
| Hill
37:16 | 28:1
images | 52:12 85:25 | 36:9,18,22,24 | 100:2,3 105:20 |
| Hing
1:13 2:13 | imagine
64:1 | 93:6 98:15,19 | 39:22 41:1 | 107:12,19 |
| 4:8 5:7 66:1 | 91:4,6,13 | instruction | 44:17 95:12,13 | 109:7,16 |
| 1:5 2:5 12:23
Ho | iMessage
28:19 | 66:15 | 95:15 109:9 | knowledge |
| 13:2,3 | iMessages
28:20 | 46:21
intentions | Jeffrey
83:5 | 19:23 31:12 |
| hold
36:13 76:16 | 109:25
impacted | interaction
42:3 | 5:2,10
joined | 67:13 87:24 |
| holder
89:14 | 15:15
important | 42:14 | 53:3
Julie | 88:8,19,20 |
| 90:3 | 66:15 | interactions | jumps
95:18 | 109:22 |
| home
9:15 10:4 | impression | 37:24 38:21 | June
75:25 | known
69:17 |
| 17:14 61:9 | 21:14 38:23 | 43:14 58:10,19 | K | 89:22 |
| 62:2,3,6,18 | in-person
69:3 | 106:6 107:25 | kept
97:23 | Krasner
14:12 |
| 77:1 88:16 | 72:7 | 108:16 | | 17:13 20:25 |
212-400-8845 - Depo@TransPerfect.com TransPerfect Legal Solutions
| 21:4 26:22,23 | lawsuit
67:22 | 101:18 | looks
11:1 28:24 | making
38:24 |
|--------------------|----------------------|----------------------|---------------------|---------------------|
| 29:7,11,18,19 | 73:2
lawyer | 11:24
lists | 96:3 | 39:4 50:21 |
| 31:2 32:1,4,11 | 80:15 88:15,15 | 33:9
literally | 11:19 14:14
lot | 108:3,19 |
| 32:16 34:25 | 89:10,15 90:4 | litigation
6:9 | 80:23 81:1,16 | man
23:17 |
| 35:3,14 39:24 | 90:11 98:7,21 | little
22:9 27:12 | 81:19 | managers
59:13 |
| 40:11,21 44:5 | lawyers
13:24 | 31:22 92:3 | low
11:15 | 59:14 |
| 44:17 52:23 | 47:17 49:21 | live
11:17,17 | lowered
46:4 | Mandarin
69:24 |
| 56:19 60:24 | 86:13 | 17:5 | 1:9 2:9 3:3
Luc | 70:3 100:2 |
| 84:7 90:15,18 | lay
6:17 | lived
42:15 | 4:6,25 6:7 | 103:13,23 |
| 90:23 91:1,10 | left
9:1 29:3,19 | LLC
1:12 2:12 | 70:14,14 77:10 | March
60:23 |
| 91:21 92:10,13 | 33:8,16 36:19 | 4:8 5:8 22:3 | 80:18 | 81:8 |
| 94:17 105:24 | 39:9 86:14 | 50:3,7,12,14 | Luft
73:19,20 | Margaret
52:24 |
| 106:2,10,17 | 28:25
left-hand | 50:18 51:3,16 | 77:19 | 53:23 |
| 107:1,4,25 | 29:5 44:3 | 51:19 52:10 | 11:7,14
luxury | 10:16 18:6
mark |
| 108:17 | legal
33:11 | 54:17 66:2 | Luyi
5:3 | 27:22 48:21 |
| Kruger
101:10 | 81:15 109:17 | 98:4,9,13 | | 52:5 |
| 101:12,24 | legitimate
21:21 | 99:10,14,19 | M | marked
10:18 |
| 109:4,12,25 | let's
98:17,17 | 100:11 107:21 | Mac
28:15 97:14 | 18:10 27:19,25 |
| 1:5 2:5
Kwok | 99:3,7
liability | 108:8
LLCs | 97:24 | 48:18 52:2,14 |
| 12:23,25 13:2 | license
9:7 | local
11:19 | Major
3:13 5:5 | 55:17,22 84:17 |
| 13:3 114:3 | licensed
8:11 | location
2:18 | 5:6 6:20 13:14 | 105:6,9 |
| | liked
14:10,14 | 74:25 76:9 | 13:21 14:7 | market
34:5 |
| L | 25:9 38:4,7 | locations
74:23 | 17:16,21 21:12 | marriage
113:15 |
| label
48:24 | 58:23 64:17 | 7:5 8:19
long | 22:5,7 23:3 | 69:9
married |
| 52:15 55:25 | 17:3
likes | 77:17 | 28:3 29:22 | 83:5
Martha |
| 18:14
labeled | limit
26:8,14 | longer
14:23,24 | 32:6,17 33:7 | matter
4:6 12:21 |
| 78:19
Laff | limited
70:11 | 31:19 33:6 | 35:5 38:1 39:1 | 50:11 66:4 |
| land
1:12 2:12 | 99:3,6 100:3 | look
10:23 11:6 | 39:6 40:6,14 | 71:13 113:16 |
| 4:8 5:8 6:17 | Lindsay
80:19 | 22:11 23:24 | 40:18,23 43:3 | matters
85:25 |
| 50:3,7,14,19 | 81:5
Lindsay's | 36:6,11,16 | 43:17 44:20,25 | 57:1
Matthew |
| 51:3,16,19 | line
19:1,13 | 37:6,7,14 53:2 | 46:2,14,18 | Max
14:12,25 |
| 52:10 53:25 | 24:17 25:17 | 53:2 56:11 | 47:1,5,21 | 15:1 16:25 |
| 54:7,17 64:7 | 53:5 62:12 | 74:21 75:1 | 49:15,18 50:8 | 19:5 27:7 29:4 |
| 66:2 98:4,9,13 | 71:9 114:9,11 | 91:12 95:8,11 | 50:15,24 51:4 | 35:10 38:7 |
| 99:14,18 | 114:13,15,17 | 102:21 | 51:8,21 53:19 | 40:19 45:5,13 |
| 100:11 107:21 | 114:19,21 | 56:2 64:9
looked | 54:13,18,22 | 46:5,10,12,16 |
| 108:13 114:3 | lines
74:16 | 72:19 95:17 | 57:13 58:13,21 | 46:20,22 47:11 |
| language
38:18 | list
12:13,15,18 | 106:24 | 59:9 61:14,24 | 50:17 53:23 |
| 43:11,19 99:23 | 20:6 37:14 | looking
9:15,23 | 62:5,9 64:5,23 | 56:19,21 61:1 |
| 102:9 103:12 | 73:5 | 15:10 17:2,10 | 65:5,18,22,24 | 61:6,17 62:23 |
| 103:22 | 14:18 19:2
listed | 19:13 24:10,11 | 87:4 100:16 | 63:4 84:7 |
| 99:24
languages | 41:10 84:20 | 45:2 54:3 | 104:19 105:14 | 88:14,15 93:5 |
| 70:15
Lapin | 100:14 | 59:20 60:1 | 105:24 106:4 | 93:5,6 94:16 |
| 77:10 80:18 | listing
34:23 | 63:11,18,24 | 106:12 108:5 | mean
9:5 11:12 |
| large
64:10 | 38:14,17 83:12 | 64:3,6,9 76:10 | 108:15,22 | 19:9 23:4 25:7 |
| law
65:24 67:20 | 34:11,15
listings | 77:23 82:12 | 112:5 | 33:6 47:13 |
| 70:7 | 34:17 35:2 | 83:12 | majority
33:2 | 50:9 62:2 |
| | | | | |
# Case 22-50073 Doc 2292-39 Filed 10/26/23 Entered 10/26/23 20:46:12 Page 39
of 46
| 63:25 67:7,24 | 43:23 44:4,13 | 54:6,16 57:24 | money
47:17 | 56:3 |
|---------------------|-------------------|---------------------|---------------------|---------------------|
| 70:21 72:23 | 45:11 55:8 | 57:25 58:11,19 | 64:18 87:25 | negotiated
86:12 |
| 76:14 78:2 | 56:18,19 60:24 | 59:17 61:9,15 | 89:9,14 98:10 | negotiation |
| 80:13,22 83:22 | 61:12 62:22 | 61:22 62:2,3,6 | Monteith
80:20 | 69:21 |
| 85:21 88:22 | 63:3 95:12 | 62:16,20,23,24 | 33:17
months | 1:17 2:17
Neree |
| 9:6
Meaning | 96:4 | 63:6,11,15,17 | 4:22
morning | 4:6 5:17,23 6:6 |
| means
12:2 | messages
27:18 | 64:20 67:10,16 | 5:5 36:10 | 6:11 7:21 8:10 |
| meant
8:3 23:6 | 28:15,16,24 | 68:3,6,6,18,24 | 65:15 105:25 | 10:9,16,21 |
| 40:13 | 29:6,10,18 | 69:4,8 70:10 | moving
47:15 | 12:22 15:7 |
| media
10:11 | 30:24 31:1,15 | 70:19 83:14 | 59:24 60:5 | 18:7 24:5 |
| 13:7 | 32:12 36:8,18 | 84:1,3,6,10,13 | 39:19
multiple | 27:23,24 29:24 |
| meet
35:16 41:6 | 55:4 56:16 | 85:1,12,17 | 64:11 105:21 | 30:14 48:12,22 |
| 57:16,20 90:18 | 60:23 91:17 | 88:24 89:3 | | 49:2 52:6,7,14 |
| meeting
35:24 | 95:9 96:9,19 | 91:24 92:18 | N | 52:20 60:1,8 |
| 36:4,24 37:2 | 97:3,3,12,17 | 93:12,17,20 | N
3:1 112:1 | 65:14,23 88:25 |
| 41:16 45:17,21 | 97:19,22,23,23 | 95:24 98:15,19 | N-E-R-E-E
5:24 | 89:24 100:4,18 |
| 45:25 57:9,15 | 97:25 106:23 | 98:21 104:3 | nailed
26:9 | 101:4 102:5 |
| 57:25 58:3,6 | 112:13 | 105:8,15,18 | 4:15 5:21
name | 104:13,20,24 |
| 58:15 59:6,17 | met
27:9 36:15 | 106:3,7,11,15 | 19:15 23:5 | 105:6,12 111:3 |
| 59:19,24 92:8 | 68:8 69:20 | 107:9,17,25 | 35:15 36:12 | 112:2 114:5,25 |
| 104:13 107:14 | 73:20 91:4 | 108:2,13,17,19 | 52:9 63:13 | 10:17
Neree's |
| 107:15 | 92:5 105:20 | 108:23 112:19 | 65:24 68:4,7,8 | 112:10 |
| meetings
59:7 | middle
29:2,10 | Miles'
25:13 | 70:14,18 73:16 | Neuberg
80:19 |
| 59:11 60:12 | 29:20 43:23 | 35:4 46:21 | 74:8 83:2 98:8 | never
10:25 20:9 |
| 69:3 91:19 | Mile's
103:9 | 92:5,13 99:21 | 107:12 114:3,5 | 22:22,25 25:16 |
| Meister
3:10 5:6 | 107:12 | 99:24 102:6,12 | named
12:23 | 46:19 68:21 |
| 5:11 65:25 | 12:25,25
Miles | 103:24 | 50:18 51:2 | 73:20 83:20,22 |
| member
99:7,10 | 13:1,3,8,10,12 | Miles's
102:8 | 68:3,18 84:2 | 86:2 91:24 |
| 99:14,18 | 14:6 15:1 | 103:4 104:15 | 85:1,12 | 97:22 |
| 107:20 | 16:24 17:14,20 | Miller
1:21 2:20 | 13:8 68:9
names | New
1:18,18 |
| members
99:8 | 19:10,10 20:5 | 5:13 113:3,20 | 68:11,14,19,20 | 2:18,19 3:5,11 |
| 99:18 107:20 | 21:1,5,8,19 | 12:11
million | 69:14,19,19 | 5:18 71:20,21 |
| 107:21 | 22:14 23:4,7 | 39:25 40:16 | 78:2 83:20 | 75:4,8 77:14 |
| memory
37:20 | 26:18 27:3,9 | 42:12 46:5,7 | 20:3
narrow | 77:20 78:5,10 |
| 75:2 78:8 | 32:5 34:5,10 | 64:17 | 14:5
nature | 78:15 82:3 |
| mentioned
23:9 | 35:1,22 36:10 | mind
37:13 | near
63:5,19 | 102:16,17 |
| 68:11 70:7,15 | 36:15,19 37:4 | minutes
6:16 | 80:12 | 113:5 |
| 72:12 74:18 | 37:24 38:9,17 | 48:4 64:25 | nearby
61:23 | 80:21
Newhaven |
| 75:3 81:2,2,7 | 38:18 39:2,4,9 | missing
96:19 | necessarily | 81:8 |
| 104:2 | 40:8,24 41:5 | 97:2,3 | 12:18 64:8,9 | Ngok
1:13 2:13 |
| mentioning | 41:19 42:3,22 | mistake
76:24 | necessary
24:20 | 4:9 5:7 66:2 |
| 109:15 | 43:2,7,15 44:7 | 77:13 | need
7:6,10 | nice
41:6 64:12 |
| 30:19
message | 45:7,20 46:16 | 34:19,20
MLS | 78:24 79:11 | 3:7
NICHOLAS |
| 34:1,24 35:7 | 46:20 47:2,8 | 18:5
moment | needed
36:13 | nicholasbasset |
| 35:13 36:2 | 47:23 49:12 | 27:13 30:9 | 71:22 73:9 | 3:6 |
| 39:8,23 41:2 | 50:14,21 51:11 | 104:12 110:3 | 24:21 25:4
needs | Nick
4:23 6:6 |
| 41:12,14 42:15 | 51:20 53:25 | Monday
47:14 | Neere
55:23 | nine
33:17 |
212-400-8845 - Depo@TransPerfect.com TransPerfect Legal Solutions
| nonbinding | 51:8,21 53:19 | 39:24 40:15 | opposed
72:6 | 19:19 24:1,3 |
|-------------------------------|---------------------|----------------------|---------------------------------|---------------------|
| 49:19 | 54:13,18,22 | 42:20,23 46:5 | options
95:24 | paraphrase |
| nondisclosure | 57:13 58:13,21 | 46:11,24 47:7 | 21:5
order | 53:14 |
| 16:4 | 59:9 61:14,24 | 47:9,13 48:16 | ordering
110:11 | Park
3:4,10 |
| noon
35:10,17 | 62:5,9 64:5,23 | 49:6,8,12,16 | orient
28:23 | part
23:25 58:14 |
| 45:13 56:21 | 66:25 70:4 | 49:17,19 51:15 | oriented
29:9 | 79:5,9,24 |
| Notary
5:18 | 72:21 76:13 | 52:12 54:24 | original
12:15 | participants |
| 111:9 113:4 | 78:1 84:23 | 56:3 81:20,23 | 22:24,24 | 4:14 |
| 71:6
notes | 85:3,13,19 | 86:11 112:14 | 26:22
originally | 85:6
participate |
| notice
23:5 | 86:8 87:4,16 | offered
46:6 | out-of-pocket | participated |
| noticed
81:1 | 88:2 89:6,11 | office
63:5,11,18 | 25:18,22 26:2 | 85:8 |
| notices
73:6 | 89:16,20 90:6 | 63:24,25 78:25 | outcome
113:16 | particular
26:7 |
| notifications | 90:13,24 93:2 | official
33:22 | Outlook
8:5 | 94:12 99:1 |
| 71:16 | 93:15,22 96:10 | 72:10 86:2 | 30:24
outside | 113:14
parties |
| notified
72:2 | 96:21 97:5,15 | Oh
72:2 | overlooking | partner
5:10 |
| notwithstandi | 97:20 98:1,5 | okay
6:15 8:10 | 64:11 | 101:8,10 109:4 |
| 102:9 | 98:22 101:14 | 8:14,23 10:7 | owned
19:6,8,10 | 109:8 |
| November
30:15 | 105:14 106:4 | 12:17 16:9,18 | 21:1,15 90:9 | parts
58:9,17 |
| 31:6,13 34:2 | 106:12,20 | 17:18 19:11 | 99:3,7 | 65:20
pass |
| 27:5
number | 108:5,15,22 | 20:22 23:20 | 41:4
owners | 96:8
passage |
| 35:15 36:13 | objections
7:14 | 26:4,16 29:5 | owning
85:17 | Patrick
80:19 |
| 42:13 | 66:10 88:11 | 35:12 36:16 | owns
90:12 98:3 | Paul
3:4 4:23 |
| numbers
55:7 | obligated
25:18 | 37:2 38:18 | 98:12 | 5:3 67:17,19 |
| NY
3:5,11 | obligations | 40:20 41:16 | | 67:20 70:7,9 |
| | 23:25 24:18 | 42:1,24 43:6 | P | 71:12,25 73:13 |
| O | observe
58:9 | 46:23 50:2 | P
3:1,1 | 73:22 76:9,12 |
| 6:24 101:5
oath | 103:3 | 56:7 59:5 | 61:7,19
p.m | 76:19 77:6,24 |
| object
26:19 | observed
58:19 | 60:20 63:2 | 95:12 100:24 | 78:14,22 80:1 |
| 29:22 30:1 | obtain
28:5 | 65:5 66:11,14 | 110:9 | 81:10 82:4,8 |
| 74:6 78:16 | 10:22
obtained | 66:21,23 67:21 | page
11:4 18:15 | 82:18,21 101:8 |
| 79:4 89:7 | 6:19
obvious | 71:24 75:3 | 22:12,21 28:25 | 109:5,8 |
| 99:25 101:21 | 11:14 | 91:16 94:10 | 29:5 40:25 | pause
30:8 |
| 104:1 | obviously
11:3 | 95:16 98:17 | 43:24 49:1 | pay
25:18 |
| objection
7:16 | 60:15 84:7 | 100:19 105:2 | 52:17 53:4 | payment
85:23 |
| 13:14,20,21,22 | occasion
91:18 | 109:11 110:6 | 55:7,25 56:12 | 95:3 |
| 14:7 17:16,21 | occasions | 91:1,7
old | 63:3 95:13 | 20:11
Pecksland |
| 21:12 22:5,7 | 105:21 | once
10:10 | 112:3,9 114:9 | 35:11,17,21 |
| 23:3 28:3 30:9 | occur
45:17 | 13:23 16:12 | 114:11,13,15 | 37:7,13,16 |
| 32:6,17 33:7 | occurred
6:23 | 69:20 71:18,19 | 114:17,19,21 | pending
7:11 |
| 35:5 38:1 39:1 | 35:24 36:4 | 71:19 74:18 | pages
29:15 | people
81:1 |
| 39:6 40:6,14
40:18,23 43:3 | 37:3 45:25 | 86:10 | 60:22 80:25
paid
25:24,25 | 107:5 108:7 |
| | 47:20 57:10 | one-year
44:16 | | Pepe
80:20 |
| 43:17 44:20,25
46:2,14,18 | 58:11 59:7 | ones
29:9 32:24 | 87:8,10 92:18
92:25 93:4,8 | perfect
34:4 |
| 47:1,5,21 | October
15:2 | 72:3,3,9 | 93:25 94:16,20 | performed |
| 49:15,18 50:8 | 16:7,20 | open
10:10 26:6 | pains
97:7 | 92:22 |
| | 10:4 15:21
offer | 32:20 83:11 | | 14:9,23
period |
| 50:15,24 51:4 | 15:23 38:25 | 34:21
openable | paragraph | 45:4 |
| person
12:23 | pleasure
6:12 | 72:17 86:17,23 | 20:13 21:5,9 | purchases
108:9 |
|---------------------|---------------------|---------------------|---------------------|----------------------|
| 26:23 27:9 | 41:6 | 87:1,8,20 | 21:17 22:3 | purchasing |
| 46:8 68:23 | 3:10
PLLC | 20:14
Private | 35:25 37:7,13 | 61:21 108:24 |
| 69:3,7 70:19 | 65:10 101:1
PM | 98:20
privy | 37:20 38:13,25 | 57:14
purpose |
| 73:17,20,22 | 101:1 110:24 | probably
12:15 | 40:5 41:14,17 | 57:16 59:15 |
| 78:14,19,22 | point
13:11 | 26:9 36:5 | 42:9,17,22 | 63:23 |
| 83:23 84:2 | 20:15 38:10 | 60:13 80:12 | 43:8 45:16 | purposes
13:25 |
| 85:16,22,22 | 40:19 41:15 | 82:14 96:12,14 | 46:3 49:13,17 | pursuant
75:9 |
| 90:19,22 | 67:18 69:17,20 | 110:21 | 50:12,22 51:13 | 74:1
push |
| 105:13,16 | 70:14 71:16 | proceed
5:16 | 51:20 56:4 | put
10:8 27:14 |
| 106:9,15,16 | 79:12,17,20 | 6:18 16:15 | 59:8,12,13,14 | 30:10 48:14 |
| person's
68:4 | 82:24 | 21:24 | 59:18 60:12 | 49:21 50:18 |
| personal
24:22 | possibility
97:2 | proceeding
1:13 | 61:8 64:10 | 51:24 55:11,14 |
| 25:5 60:2,17 | 24:8
possible | 5:2,9 66:1 67:4 | 67:4,7 69:21 | 105:4 |
| 107:8
persons | 37:11 47:25 | 74:10 96:4 | 70:10 85:18 | |
| perspective
9:21 | 58:25 78:17 | proceeds
87:21 | 86:6 88:1 | Q |
| 18:20 | 97:11 | 90:4,10 | 91:20 92:14 | qualifications |
| phone
27:5 | postponed
73:25 | process
35:4 | 102:6 104:10 | 24:22 25:5 |
| 28:12,13,18 | potential
32:19 | 44:22 | 106:3,18 107:2 | question
7:1,11 |
| 35:15 36:13 | 101:9,13 | 28:7
produced | 108:4,9,20,25 | 7:13,18 14:1,3 |
| 71:6 97:13,18 | potentially | professional | property's
67:11 | 14:4 21:6 25:1 |
| photo
68:23 | 61:22 | 13:12 | proposals
41:9 | 30:6,8 31:24 |
| pick
39:10,14 | practice
11:10 | profile
10:22 | proposing
41:7 | 38:15 44:12 |
| picture
11:4 | preferences
9:20 | promise
23:15 | protection
20:20 | 51:9 66:7 |
| 105:5,8,13 | 73:23
presence | promoted | 9:17
provide | 87:19 92:17 |
| 112:19 | present
3:18 | 101:17 | 60:14 | 97:9 102:7 |
| pin
55:11 | 37:4 38:15 | proof
86:1 | provided
16:16 | questioning |
| place
4:12 15:4 | 41:19 43:16 | properly
109:18 | 79:25 82:4 | 4:21 89:1 |
| 16:3 41:17 | 45:20 58:7,14 | properties
11:25 | 87:25 | questions
6:20 |
| 47:14 70:2 | 58:17 59:2 | 11:25 14:8,18 | 24:20
providing | 6:22,25 7:15 |
| 71:1,5 84:11 | 107:16 | 14:20 17:2,11 | 23:9
provision | 24:2,15 30:2 |
| 103:12,22 | presents
20:17 | 20:4,7,7,10,16 | Public
5:18 | 38:10,12 41:11 |
| plaintiff
1:10 | presumably | 21:24 23:12 | 111:9 113:4 | 43:8 52:8 65:1 |
| 2:10 5:1 6:8 | 73:8 | 27:8,10 32:19 | purchase
9:15 | 65:16,18,19 |
| 67:22 | previous
59:13 | 34:4,20 35:22 | 15:21,24 21:16 | 66:3,5,11 |
| 4:18 5:20
please | 81:13 | 36:11,21 37:8 | 48:16 49:6,8 | 80:23 92:3 |
| 7:2 10:15 | previously
82:4 | 37:14 39:10,19 | 49:20 51:15,20 | 102:4 104:21 |
| 13:18 14:5 | price
12:19 | 40:9 41:23 | 53:8 57:6 | 104:24 109:2 |
| 17:24 18:6 | 42:11 45:8 | 44:7 61:23 | 64:21 74:9 | 110:5
24:15 |
| 27:22,23 29:25 | 46:3,6 | 64:14,21 67:12 | 81:21 86:6,18 | quick
42:20 47:13 |
| 30:7 41:3 44:8 | 11:15
priced | 99:2 106:25 | 87:21,25 88:9 | 48:3 |
| 48:15,21 51:24 | 12:13,16
prices | 109:3 | 88:16 90:4,10 | 14:3
quickly |
| 51:25 52:5 | primarily
8:15 | property
9:19 | 98:8,10,16,20 | 42:18 43:5 |
| 55:14 58:18 | print
79:23 | 9:22 10:5 11:7 | 99:16 100:6 | 47:20,24 |
| 66:7 76:17 | printed
28:17 | 12:7,8,10 15:3 | 104:17 106:18 | quote
62:13 |
| 95:25 104:12 | 78:3 | 15:23 16:2 | 108:20 112:14 | |
| 105:4 110:4 | 49:11
prior | 17:19 18:20 | 83:14
purchased | |
of 46
| R | recognize
49:2 | relationship | 4:16 5:14 9:14 | 89:4,19 91:25 |
|----------------------|---------------------|---------------------|---------------------|---------------------|
| R
3:1 80:19 | 52:19 96:8 | 13:12,15,19 | 21:19 46:9 | 94:13 96:4 |
| 113:1 114:2,2 | 105:12 | 14:6 16:19 | 66:9 84:12 | 99:4,11 103:16 |
| Raft
78:19 | recollect
37:9 | 17:12 21:10 | request
79:6,10 | 103:25 104:3 |
| 32:9
range | recollection | 50:13 109:3,24 | 80:17
requested | 106:19 108:4 |
| reached
21:4 | 16:21 28:7 | release
54:1 | 81:17 | 112:11 |
| reaches
63:4 | 39:18 40:10 | released
53:17 | required
73:23 | right-hand |
| read
80:24,25,25 | 42:2 45:24 | remember
19:14 | research
21:21 | 22:12,20 48:25 |
| reading
53:11 | 46:4 57:11 | 28:16 45:6 | reserve
65:17 | 52:16 55:24 |
| 8:11,19 9:7
real | 75:24 103:7 | 61:17 62:22,25 | residential | 12:8 20:11
road |
| 9:9 11:9 15:24 | recommended | 69:16,19 77:8 | 55:15 99:2 | 20:12 35:17,21 |
| 21:25 46:8 | 102:2 | 77:10,11 78:21 | 112:17 | 37:7 39:25 |
| 48:17 49:6,8 | reconstruct | 81:11,12 83:2 | respect
108:12 | 40:3,5,9,16 |
| 51:15 55:15 | 15:19 | 96:15 101:16 | 108:19 | 45:14,18 46:25 |
| 94:6 101:9 | 4:2 5:22
record | 101:25 102:13 | respectfully | 49:10 53:6,8 |
| 112:14,17 | 7:20 18:13 | 102:14 103:5 | 41:4 | 56:4 59:8 61:8 |
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15:20 | 24:6 48:6,11 | 107:2,22 109:5 | respond
30:5 | 62:1,2 64:16 |
| 25:7 42:18 | 48:23 52:15 | 109:20 | responded
80:14 | 70:12 86:6,19 |
| 83:3 90:23 | 55:22 65:7,12 | remind
97:6 | responds
35:12 | 87:22 88:9 |
| realtor
5:24 | 88:6 100:20,23 | Remote
2:18 | response
28:8 | 92:4,9,19 |
| 73:3 108:8 | 101:3 110:8 | 4:14
remotely | 92:2,17 | 94:12 95:4 |
| 7:7 19:25
reason | 113:10 114:7 | renovations | responsibilities | 100:6,13 102:6 |
| 36:14 66:18 | redact
60:16 | 57:19 | 88:18 | 104:14,17 |
| 74:2 94:24 | refer
13:10 16:7 | rephrase
7:3 | responsive | 106:19 108:4 |
| 96:23 97:10,22 | 60:12 69:3 | 51:9 | 60:13 | 108:20,25 |
| 106:8 114:6,9 | 40:4
reference | 9:25
report | 18:21
retaining | 7:21 38:2
room |
| 114:11,13,15 | 41:14 62:15 | 59:16 94:15,16 | 109:9
retired | 76:23 |
| 114:17,19,21 | referenced
25:4 | 94:18,24 | review
44:8 | rough
110:15,21 |
| recall
31:5 37:23 | referrals
101:23 | REPORTED | 95:25 | roughly
8:21 |
| 41:13 49:13 | referred
68:5 | 1:21 | reviewable | 16:20 |
| 59:17 71:2 | 78:19 101:13 | reporter
5:13,15 | 34:22 | Round
37:16 |
| 74:15 75:12,21 | 18:1
referring | 5:20 10:15 | 33:17
rid | 20:12
Roundhill |
| 77:6 78:12 | 57:23 62:7,11 | 18:5 27:22 | ridiculous
97:16 | rules
66:6,11 |
| 79:25 92:22 | 68:2 69:8 | 30:10 48:21 | right
4:3 8:24 | |
| 93:4 94:1 | 84:15 105:17 | 52:5 110:10,14 | 15:22 18:1,8 | S |
| recalling
94:11 | 106:1,17 | 110:18 113:4 | 18:17 23:22 | S
3:1 80:19 |
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23:21 | 36:23
refers | 4:20
represent | 29:4 32:24 | 112:8 114:2 |
| 25:2,12 94:14 | 42:16 | 5:7 6:7 9:10 | 44:18 49:25 | sailor
11:16 |
| 100:5 | refresh
39:18 | 15:22 18:2,9 | 50:23 51:16 | 12:4 23:17
sale |
| received
75:4 | regarding
16:1 | 18:18 32:25 | 56:8,13 65:16 | 23:19,20 87:15 |
| 82:22 86:17,23 | 25:13 70:9 | 65:25 84:9,13 | 65:17 73:11 | sales
10:12 11:2 |
| 86:23 98:7 | 95:4 | 112:12 | 74:20 76:8 | 11:24 55:16 |
| 8:7
receiving | 23:17
regardless | representation | 77:4,16,25 | 56:5 112:17 |
| 76:20 | regards
33:21 | 81:21 | 79:6 83:15 | salesperson
8:13 |
| recess
48:8 65:9 | related
26:18 | represented | 84:13,16,19 | 8:14,20 9:10 |
| 100:25 | 49:16 109:13 | 101:7 109:18 | 85:2 86:20,21 | 21:25 |
| | 113:13 | representing | 86:24,25 87:14 | Saturday
36:7 |
| saw
22:22,25 | 61:9,10 62:14 | set
14:16 61:19 | size
80:5 | 97:8 |
|---------------------|---------------------|----------------------|----------------------|---------------------|
| 72:3 81:20 | 62:18,23,25 | 73:10 113:8 | 45:5
sky | 89:2
speculating |
| 53:15,18
saying | 63:7 67:3 | 30:3
setting | 42:21
slower | 6:16
spend |
| 57:22 | 68:22 80:4 | share
86:23 | small
22:16 | spoke
22:9 70:8 |
| says
11:6,24 | 82:17 93:12,17 | short
23:17 | social
10:11 13:7 | 77:7,8 80:14 |
| 19:14,19 22:13 | 95:20 96:1 | 42:19 | sold
12:1 109:4 | 91:9 104:4 |
| 23:25 24:17,18 | 100:12 107:1 | Shorthand | somebody
75:12 | spoken
43:12,20 |
| 26:15 28:19 | 34:11
seeing | 113:4 | 76:22 | 71:11 77:15,19 |
| 30:15 34:2 | 35:1 | show
14:20 | son
69:23 92:5 | 78:9 109:11 |
| 35:12,14,16 | Seelig
3:10 5:6 | 16:10 17:6,8 | 92:13 102:6,12 | Stamford
71:19 |
| 36:18,19 39:8 | 5:11 65:25 | 17:23 23:13 | 102:14,17 | 74:19,25 77:5 |
| 39:24 41:2 | seen
10:25 22:1 | 37:15 40:8 | 103:3,9,24 | standard
18:19 |
| 42:24 44:5 | 74:7 | 48:12 55:12 | 104:3,15 | 24:12,13 |
| 45:12,15 50:2 | 12:11
sell | 74:19 75:4 | 107:16 | 66:8 105:3
start |
| 50:3,3 56:12 | seller's
59:23 | 76:7 107:5 | Song
5:3 | started
17:12 |
| 56:20,25 60:5 | 86:13 87:10,13 | showed
14:8 | soon
34:9 81:9 | starting
75:7 |
| 61:5,15 63:3 | 89:9,15 90:4 | 20:12 37:20 | sorry
13:17 | starts
55:23 |
| 76:8 95:22 | 90:11 | 45:7 85:22 | 22:18 46:17 | 60:24 96:6 |
| 79:23
scanned | 9:11
sellers | 107:8 | 52:13 55:6 | 4:19 5:18
state |
| scenarios
22:1 | 42:14 46:8,9 | showing
27:10 | 56:15 76:24 | 5:20 6:19 |
| scheduled
61:1 | 53:15,24 | 35:22 37:10 | 77:12 | 67:25 113:5 |
| 61:6 | selling
8:15 | 61:2,7 106:25 | sort
14:15 16:6 | statement
54:11 |
| scratch
76:14 | 86:13 | showings
14:17 | 21:7 32:23 | States
1:1 2:1 |
| 8:4,4
screen | 32:19
send | 23:16 90:16 | 55:11 | 4:9 |
| 10:8 24:7 | 34:20 79:2 | 16:14
shown | 56:13
sounds | 37:12
sticks |
| 51:25 | 81:9 82:7 | 20:5,9 30:25 | 83:6,7 | stockholder |
| scroll
52:18 | sending
87:14 | 31:2 32:24 | source
86:5 87:2 | 99:11 |
| search
9:18 | 87:15 | 37:11 39:20 | 87:7,21 88:8 | stopped
44:23 |
| second
12:7 | sent
29:6 32:22 | 41:23 91:16 | 95:2 98:14,14 | stories
68:16,17 |
| 36:17 42:7 | 34:1,12,16,17 | 28:1,16
shows | 63:5,12,18
space | 64:12
stream |
| 53:4 62:12 | 34:25 39:24 | sic
70:15 77:11 | 63:24,25 | Street
80:20 |
| 69:22 74:24 | 61:17 79:23 | side
12:4,6 28:25 | speak
69:24 | strike
31:23 |
| section
20:1 | 82:12,16,17 | 44:3 | 102:12 | strong
37:19 |
| security
42:5 | 89:9,14 90:3 | signature
19:13 | speaking
7:16 | student
102:16 |
| 57:2 | 90:10 | 78:3 80:10,10 | 38:19 78:21 | 102:17 |
| 7:18 14:2,13
see | sentence
62:12 | 80:11,11 81:5 | 82:19 90:22 | study
102:20 |
| 18:24 19:19 | 96:6 | signed
16:5 | speaks
99:24 | stuff
60:17 |
| 22:15,19,22 | separately
94:19 | 32:23 76:11 | specialist
11:8 | 72:11 86:16 |
| 24:24 25:20 | 94:21 | 77:24 84:2,7 | specializing | subject
20:13 |
| 30:16 34:6,7 | 94:19
septic | 23:2
signifies | 57:19 | 53:5 66:4 |
| 34:13 35:18 | 44:13
sequence | 32:11
similar | 77:11
specific | 20:6
submitted |
| 36:6 39:15 | series
6:20 | sir
76:17 95:7 | 103:6 | 82:1 |
| 40:1 43:25 | serve
78:6 | 97:9 104:13 | specifically | subpoena
28:8 |
| 44:10 45:9 | served
71:17 | sitting
6:12 | 81:15 94:10 | 60:14 71:17 |
| 50:4 54:2,9 | 75:12,13 78:4 | situation
25:15 | 101:16 102:1 | 72:11 73:11 |
| 56:23 57:3 | 9:16
services | 41:5 | 103:6 | 74:13 75:4,9 |
| 59:10,21 61:3 | 18:21 | six
24:1,3 | speculate
66:18 | 75:13 76:5,11 |
76:20 77:23 80:3 **subpoenaed** 72:13 74:19 82:24 83:1,10 109:15 **subpoenas** 82:22 **Subscribed** 111:6 **subsequently** 20:8 38:6 42:22 102:3 **substance** 109:12,21 **suggest** 36:23 **sunglasses** 36:19 39:9 **supplied** 33:20 79:15 80:16 **supposedly** 68:19 **sure** 7:5,8 22:23 28:13 67:25 73:2 88:5 103:5 109:18 **surmised** 62:21 **surprise** 102:1 **swear** 5:15 **sworn** 5:17 111:6 113:8 **system** 94:20 **T T** 112:8 113:1,1 114:2,2 **tab** 10:8 17:24 27:15 48:14 51:24 55:14 95:10 **Taconic** 12:7 20:13 37:16 39:25 40:3,5,9 40:16 45:7,14 45:18 46:1,25 49:10 53:6,8 53:24 54:5,16 56:4,22 57:1 59:8 60:5 61:2 61:7,21 62:8 62:11 69:23 70:11 74:9 86:6,19 87:22 88:9 92:4,8,19 94:12 95:4 100:6,13 102:6 104:14,17 106:18 108:3 108:20,25 **take** 7:13 15:4 44:13 48:3 52:17 64:24 70:25 100:17 101:12 **taken** 2:17 15:14 48:8 65:9 71:5 100:25 103:21 **talk** 60:18 83:23 98:17 **talked** 58:23 102:19 **talking** 12:9 15:3 41:22 59:3 106:24 **talks** 25:17 **technically** 37:17 60:13 **telephone** 33:3 96:12,15 **tell** 9:16,22 14:10 30:20 47:17 73:8,23 74:4 76:15 78:23 108:23 **tend** 11:21 **term** 26:8,15 49:21 **terminate** 26:5,5 **terms** 6:17 9:20 **testified** 5:19 20:24 21:3 50:20 51:11 66:4 83:25 92:2,16 98:25 105:23 107:19 108:7 **testify** 66:16,19 74:14 **testifying** 67:23 **testimony** 105:17 107:11 110:1 113:10 **text** 7:24 27:4,18 28:1,14,16 29:17 30:24 31:1,5,8,15 32:12,21 33:3 34:1 35:7 36:8 36:18 39:8,22 41:2 43:23 44:16 55:3,8 56:16,17,18 60:23,23 61:12 63:3 91:16 95:8,11,18 96:19 97:2,3 97:25 106:23 112:13 **texted** 91:24 **texting** 91:21 106:25 **texts** 15:19 79:19,20,23 91:12 **thank** 14:21 18:3 27:17 30:11,13 31:18 65:14 104:19 **thanks** 6:9 23:11 35:13 **thing** 7:10 20:2 52:18 80:5,24 **things** 17:7 32:25 47:23 59:14 60:4 66:19 73:6 **think** 16:11,14 20:24 21:3 24:4,6 36:20 37:3 42:15 44:6 46:10 48:1 56:18 60:9,9 70:14 71:18 75:7,11 77:21 80:8 84:14 91:11 95:23 **thought** 14:19 64:17 74:25 83:22 **thousand** 94:2 **three** 27:15 71:18 **time** 4:3,4 6:9,13 6:14 7:6 9:1,4 12:19 15:17 17:10 19:13 21:17,22 26:5 26:10 29:25 36:15 37:15,18 39:14,20 40:16 41:6 42:24 43:1 48:6,11 52:9,18 64:15 65:2,7,12,14 65:19 69:2,22 70:8 74:4 77:17 79:17 80:9 88:17 91:9,11 99:16 100:23 101:3 101:11 102:5 104:20,22 107:5 110:17 **times** 22:4 52:24 71:18 104:5 107:1 **timing** 72:5 74:1 75:16 **title** 85:17 **today** 4:17 5:13 6:10 7:6,15,21 12:9 13:10,23 16:10,11 45:14 56:22 60:19 66:4 68:3 71:12 75:18,20 76:25 81:20 84:18 110:1 **today's** 4:2 6:17 110:7 **told** 19:5,12 20:25 47:6,8 54:23 62:19,24 63:17 67:11,15 67:17 79:12 81:23 102:15 105:25 106:15 107:4 **Tom** 101:10 109:4 **top** 28:19 30:14 41:1 88:25 **totally** 31:11 **train** 77:4 **transaction** 12:19 15:3 26:6 33:22 47:12,20 84:10 85:7 101:9 **transactions** 10:11,18 11:20 85:11 101:20 112:10 **transcript** 110:12 113:9 **transcription** 114:8 **transfer** 85:23 86:4 93:1,21 **translating** 103:18 **TransPerfect** 4:17 5:14 **traveled** 75:8 77:14 82:3 **traveling** 77:20 78:10,15 **trucks** 47:16 **true** 29:13 31:4 113:10 **Trustee** 1:9 2:9 3:3 4:7,25 6:8 28:7 66:9 80:19,22
> 212-400-8845 - Depo@TransPerfect.com TransPerfect Legal Solutions
| 6:25
truthfully | 50:6 51:1,6 | 47:16 | 34:16 47:15 | Y |
|---------------------|----------------------|---------------------|---------------------|---------------------|
| truthfulness | 54:15,19,21 | walk
102:25 | 78:7 | 13:1,6 15:8
yeah |
| 110:1 | 63:23 64:3 | 103:8 | went
13:7 17:7 | 17:25 18:16,25 |
| try
7:3 24:6 | 108:1,18 | walking
45:15 | 47:12 68:10,14 | 19:21 22:22 |
| 28:23 | understood
9:9 | 104:6 | 71:21 77:1 | 23:6 24:3 29:3 |
| 12:1
trying | 11:23 12:17 | 20:15
Wallacks | 83:11 98:11 | 33:14 49:19 |
| 21:11 59:10 | 13:9 14:2 15:6 | 41:15 69:20 | 64:14
weren't | 53:12,13 54:4 |
| 96:25 | 16:9 17:18 | want
7:8 24:9,14 | wife
42:6 69:20 | 54:4,10 55:5,9 |
| Tuesday
30:21 | 20:22 21:18 | 48:12 54:8 | 92:5,13 99:21 | 56:6,13 60:3 |
| turn
77:2 | 23:8,24 24:14 | 55:12 66:14,18 | 99:24 102:6,8 | 61:4 63:20,21 |
| turnaround | 32:5 33:4,25 | 88:5 89:1,24 | 103:4,9,24 | 68:16 76:2,21 |
| 110:17 | 37:22 49:23 | 91:6 102:4 | 104:3,15 | 79:5,9 81:7 |
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76:25 | 50:21 64:19 | 110:14 | 107:12,16 | 95:10,10,21 |
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12:21 | 73:4 108:11 | wanted
14:13 | 108:24 | 100:21 110:20 |
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69:20 | United
1:1 2:1 | 24:1 42:17 | willing
47:7,8 | year
9:2,7 14:9 |
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19:19 21:10 | 4:9 | 43:5 47:23,24 | wire
93:1,21 | 14:22 33:15 |
| 37:12 41:9 | 30:3
unnatural | 54:24 57:20,21 | withdrawn | 44:23 76:2 |
| 42:8 69:23 | unrecognizable | 61:9 62:14,17 | 99:22 | 84:11 91:14,14 |
| 78:7 83:19 | 19:15 | 62:23,25 | withdrew
42:23 | 95:19 96:6,8 |
| 86:12 | unusual
50:10 | wanting
17:14 | witness
5:16,23 | 109:10 |
| type
9:22 | unusually
47:13 | Warren
35:15 | 30:12 65:20 | years
11:2 |
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types | 32:19
upcoming | 36:12 | 66:17 76:18 | Yep
10:14 |
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| | 24:7 108:8 | 26:10 58:6 | 103:11 112:2 | yesterday
36:21 |
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42:4 | 59:2 64:8 | 113:7,11 114:5 | 36:23 39:10 |
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15:2 | | 71:22 | Won
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1:18,18 |
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15:24 | V | water
11:7,15,17 | 12:23 13:2,3 | 2:18,19 3:5,11 |
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114:3 | 11:19,22 17:3 | 14:18
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42:21 | 17:4,5,9 94:22 | 33:23 71:23 | 75:4,8 77:14 |
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6:5 16:15 | 89:8 | 77:20 78:5,11 |
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99:2 | video
4:5 | 21:16 24:8 | work
8:23 63:25 | 78:15 82:3 |
| underneath | videographer | 93:5 109:25 | 101:19 106:16 | 102:16,18 |
| 22:13 | 3:19 4:1,16 | 113:15 | 8:25
worked | 113:5 |
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7:2 | 5:12 48:5,10 | WBAM_009051 | 63:15 83:16 | |
| 12:2 13:3,6 | 65:6,11 100:22 | 52:1,17 112:16 | working
35:11 | Z |
| 17:2 21:11 | 101:2 110:6 | we'll
7:5 12:9 | 63:11 64:8 | 22:16 72:6
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| 27:24 40:4,21 | VIDEOTAPED | 16:15 27:12 | works
10:1 | zooming
24:7 |
| 46:23 51:18 | 1:16 | 100:19 105:3 | wouldn't
96:5,7 | |
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20:18 38:3 | 7:24 15:3
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| 101:4 103:15 | views
64:11 | 24:10,11 31:11 | write
60:4 96:5 | |
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30:20 | 1 |
| 19:3 21:7 23:2 | 42:7,8 43:7,9 | 77:13 89:23 | 35:21 44:14 | 1
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37:25 42:8 | we've
48:1 74:7 | wrote
54:12 | 53:10 112:10 |
| 32:9 39:3 | volume
32:14 | 106:24
wear | | 114:7 |
| 40:12 43:1 | | 4:13
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| 44:21 45:1 | W | website
10:23 | 1:4,8,15 2:4,8
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34:3 | week
16:2 34:12 | 2:15 112:1,8 | 101:1 |
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| 101:1,3
1:19 | 114:7 | 49:10 53:5,8 |
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110:9,24 | 2:00
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48:4 64:25 | 200
3:4 6:1 | 56:4,22 57:1 |
| 110:19 112:10 | 2000
15:5 | 59:7 60:5 |
| 10-minute | 2011
8:21 | 61:21 62:8 |
| 100:18 | 15:2 16:8 | 69:22 70:11 |
| | 2018 | |
| 76:8
10:00 | 16:20 30:15 | 74:9 86:6,19 |
| 10:09
2:19 4:4 | 31:6,13 34:2 | 87:21 88:9 |
| 100
11:18 | 2019
18:24 35:8 | 92:4,19 94:12 |
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3:11 | 36:3,18 39:22 | 95:4 100:6,13 |
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3:5 | 41:2 44:18 | 102:5 104:13 |
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112:19 | 2020
43:24 | |
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1:6,9 2:6,9 | 44:18 49:24 | 4 |
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30:21 31:9 | 112:14
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1:19 2:20 | 5 |
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11:50 | 4:3 71:3 76:1 | 5
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8:22 35:8,14 | 21
56:12 63:3 | 112:16 |
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| 65:10
12:04 | 1:7 2:7
22-50073 | 586
20:12 37:16 |
| 3:10 20:11
125 | 30:21 31:9,14
23 | 5th
60:23 |
| 35:11,16,21 | 71:5 91:13 | |
| 37:6,15 | 23-05005
1:13 | 6 |
| 13
18:24 | 24
1:19 2:19 4:3 | 6
51:24 55:18,23 |
| 13th
36:24 80:20 | 81:8 114:4 | 112:4,17 |
| 36:18,22
14 | 112:13
27 | |
| 39:22 56:8 | | 112:5
65 |
| 64:17 | 3 | 7 |
| 15
55:8,9 56:17 | 3
27:19,23 28:1 | 7
105:7,9 112:19 |
| 57:10 59:6 | 34:1 55:3 | |
| 59:11,22,24
17th | 56:14,15,15 | 7.495
12:11 |
| 18
112:11 | 60:22 95:8,10 | 7808
1:22 |
| 18th
59:25 | 112:13 114:8 | 7th
3:10 |
| 19
41:1 53:22 | 3:38
95:12 | |
| 196
80:20 | 323
12:7 | |
| | 371
45:16 | |
| 2 | 373
20:12 37:16 | |
| 17:24 18:7,11
2 | 40:4 45:7,14 | |
| 84:17 112:11 | 45:18,25 46:25 | |
| | | |