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FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020
EXHIBIT A
FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017
NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020
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2 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF QUEENS
3 Index No.: 716943/2017
- - - - - - - - - - - - - - - - - - - -x
4 WELLS FARGO BANK, N.A., AS TRUSTEE, FOR
THE CERTIFICATE HOLDERS OF MORGAN
5 STANLEY ABS CAPITAL I, INC., TRUST
2005-WMC, MORTGAGE PASS THROUGH
6 CERTIFICATES, SERIES 2005-WMC5,
Plaintiff,
7 -against-
8 RONFAYZI INC., PEOPLE OF THE STATE OF
NEW YORK, NEW YORK CITY ENVIRONMENTAL
9 CONTROL BOARD, NEW YORK CITY TRANSIT
ADJUDICATION BOARD, NEW YORK CITY
10 DEPARTMENT OF FINANCE, JOHN DOE (Those
unknown tenants, occupants, persons of
11 corporations or their heirs,
distributees, executors, administrators,
12 trustees, guardians, assignees,
creditors or successors claiming an
13 interest in the mortgaged premises),
14 Defendants.
- - - - - - - - - - - - - - - - - - - -x
15
350 Fifth Avenue
16 New York, New York
17 January 16, 2019
11:34 a.m.
18
19 EXAMINATION BEFORE TRIAL of ALMANDO
20 IZQUIERDO a/k/a ALMANDO SEAN IZQUIERDO,
21 a witness, before Julia M. Callahan, a
22 Certified Court Reporter and Notary
23 Public of the State of New York.
24
25 Job No. CS3197153
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2 A P P E A R A N C E S:
3
4 FIDELITY NATIONAL LAW GROUP
5 350 Fifth Avenue
Suite 3000
6 New York, New York 10118
7 Co-Counsel for Plaintiff
8 BY: TERENCE WATSON, ESQ.
MARIANNE F. MURRAY, ESQ.
9
10
11 GROSS POLOWY, LLC
12 900 Merchants Concourse
Suite 412
13 Westbury, New York 11590
14 Co-Counsel for Plaintiff
15 BY: LISA M. BRADLEY, ESQ.
16
17
ALSO PRESENT: Oliver Ness, Fordham
18 University Intern
19
20
* * *
21
22
23
24
25
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2 S T I P U L A T I O N S
3
4 IT IS HEREBY STIPULATED AND AGREED
5 by and between counsel for the
6 respective parties hereto, that:
7 All rights provided by the
8 C.P.L.R., and Part 221 Of the Uniform
9 Rules for the Conduct of Depositions,
10 including the right to object to any
11 question, except as to form, or to move
12 to strike any testimony at this
13 examination is reserved; and in
14 addition, the failure to object to any
15 question or to move to strike any
16 testimony at this examination shall not
17 be a bar or waiver to make such motion
18 at, and is reserved to, the trial of
19 this action.
20 This deposition may be sworn to by
21 the witness being examined before a
22 Notary Public other than the Notary
23 Public before whom this examination was
24 begun, but the failure to do so or to
25 return the original of this deposition
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2 to counsel, shall not be deemed a waiver
3 of the rights provided by Rule 3116 of
4 the C.P.L.R., and shall be controlled
5 thereby.
6 The filing of the original of this
7 deposition is waived.
8 IT IS FURTHER STIPULATED, a copy of
9 this examination shall be furnished to
10 the attorney for the witness being
11 examined without charge.
12
13 * * *
14
15
16
17
18
19
20
21
22
23
24
25
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2 A L M A N D O S E A N
3 I Z Q U I E R D O, the witness herein,
4 having first been duly sworn by the
5 Notary Public, was examined and
6 testified as follows:
7 BY THE COURT REPORTER:
8 Q. Please state your name for
9 the record?
10 A. Almando Sean Izquierdo.
11 Q. Where do you reside?
12 A. 177-26 Ursina Road,
13 St. Albans, New York 11434.
14 EXAMINATION BY
15 MR. WATSON:
16 Good afternoon,
17 Mr. Izquierdo. My name is Terence
18 Watson. I'm co-counsel for the
19 plaintiff, Wells Fargo Bank verses
20 Ronfayzi and other parties in an
21 action currently pending in Queens
22 County.
23 Before we start today's
24 deposition, I would like to ask you
25 if you would like to adjourn the
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2 deposition, hold it on another date
3 to enable you to retain counsel to
4 represent you in connection with
5 the deposition?
6 THE WITNESS: No.
7 MR. WATSON: You would like
8 to proceed today --
9 THE WITNESS: Yes.
10 MR. WATSON: -- without
11 counsel?
12 THE WITNESS: Yes.
13 MR. WATSON: Have you ever
14 been deposed before?
15 THE WITNESS: Um.
16 MR. WATSON: Sat for a
17 deposition?
18 THE WITNESS: No. This is
19 the first time ever.
20 MR. WATSON: You've never
21 testified in court or anything like
22 that as a witness?
23 THE WITNESS: No.
24 MR. WATSON: I'd just like to
25 go over some of the ground rules to
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2 make it easier technically for the
3 court reporter.
4 If you don't understand any
5 of my questions, please ask me to
6 rephrase it and I'll be happy to
7 rephrase it or repeat the question.
8 THE WITNESS: Okay.
9 MR. WATSON: For court the
10 reporter's sake, we have to talk
11 one at a time. Let me finish my
12 question. Even if you may think
13 you know what the question is going
14 to be, let me finish my question
15 before you answer.
16 THE WITNESS: Yes.
17 MR. WATSON: All your
18 responses have to be oral so she
19 can transcribe it, type it out. No
20 shaking of the head, nodding of the
21 head or things of that nature.
22 THE WITNESS: I'll try to be
23 very clear.
24 MR. WATSON: No shaking of
25 the head because the court reporter
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2 can't transcribe the information.
3 THE WITNESS: Yes.
4 MR. WATSON: If, at any time,
5 you want to take a break, let me
6 know you want to take a break. The
7 only thing I ask is not to request
8 the break when a question is
9 pending; is that okay?
10 THE WITNESS: Okay.
11 MR. WATSON: Did you take any
12 medication today that would prevent
13 you from either understanding my
14 questions today or answering the
15 questions truthfully?
16 THE WITNESS: Only thing I
17 take is pain medication for my
18 broken finger and my leg and my
19 back, yeah.
20 MR. WATSON: We are here for
21 your deposition today in connection
22 with the action that I described
23 before, Wells Fargo verses various
24 defendants, including yourself.
25 The index number 716943/2017. I'll
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2 refer to it as the action to speed
3 things up today, okay?
4 THE WITNESS: Okay.
5 MR. WATSON: I'll also refer
6 to your current home in St. Albans,
7 the address you just provided --
8 THE WITNESS: Yes. 177-26
9 Ursina Road, St. Albans, New York
10 11434.
11 MR. WATSON: Right, 177-26
12 Ursina Road, St. Albans, I'll refer
13 to that as the property --
14 THE WITNESS: Okay.
15 MR. WATSON: -- to sort of
16 speed things along.
17 THE WITNESS: Yes.
18 MR. WATSON: If I have
19 questions with respect to other
20 properties, I'll identify them by
21 the address.
22 THE WITNESS: Yes.
23 Q. Did you meet with anyone to
24 prepare for today's deposition?
25 A. No.
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2 Q. Did you review any documents
3 to prepare for today's deposition?
4 A. Yes.
5 Q. What documents did you
6 review?
7 A. Um -- he moved out, the time
8 he moved and he came back.
9 Q. I'm sorry, who?
10 A. Walter McDowell and he was
11 out, he moved out and he came back home.
12 He moved out in 1985 to get himself
13 together and 1994 that's when he came
14 back, but he was not really back. He
15 was in and out like four more years
16 later, 1998. That's when he
17 collectively [sic] moved in because his
18 son, his son, was in the system because
19 his mother kicked his son out and he go
20 get him and show his place, say that he
21 had a place to stay for his son. That's
22 how his son was residing there in
23 1980 -- no, in 1998.
24 Q. So when you said he moved in,
25 are you talking about Walter?
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2 A. Walter, Jr.
3 Q. Walter, Jr.?
4 A. Yeah.
5 Q. Walter McDowell, Jr.?
6 A. Yes. Walter McDowell's son,
7 he was troubled by the City in 1998
8 because his mother kicked him out,
9 kicked her son out when he was, he was,
10 like one, two to three years old and his
11 father, when he got him, brought him to
12 the house. That's when he's stayed in
13 1998.
14 Q. My question was, what
15 documents did you review to prepare for
16 today's deposition; did you review any
17 documents to prepare for the deposition
18 today?
19 A. I don't know what you mean by
20 "documents."
21 Q. Did you look at any documents
22 to prepare for the deposition?
23 A. Yeah, I looked at documents,
24 yes.
25 Q. Which documents?
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2 A. I was just looking at when he
3 was moving out, in and out my house and
4 I looked at certain documents that he
5 forged when he got the property. When
6 my mother got sick in 2000, he was
7 forging records in 2001, 2002. That's
8 when he started forging documents.
9 Q. Walter, Jr.?
10 A. Walter, Jr.
11 Q. Which documents are you
12 alleging he forged?
13 A. He forged power of attorney,
14 he forged power of attorney and the
15 deed, he put it in his name. He stole
16 that.
17 There was [sic] properties in
18 the Bronx on White Plains Road. She had
19 half a block on 228th. He liquified
20 that. Where'd the 4 and a half million
21 dollars come from? The half a block had
22 six stores, a building and parking lot
23 in the back. That was half a block.
24 Crotona and Tremont, he
25 liquified that too. 1944 Tremont
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2 Avenue, he liquified that too.
3 Q. We'll get to those properties
4 and the allegations of forgery.
5 Briefly describe your
6 education background?
7 A. I didn't graduate out of high
8 school.
9 Q. How far did you get in
10 school?
11 A. I got to 12th grade. I
12 didn't graduate.
13 Q. Are you currently employed?
14 A. No, not anymore. I'm on SSID
15 now.
16 Q. Since when?
17 A. I'm just off employment
18 August, this past August.
19 Q. Since August 2018?
20 A. Yes.
21 Q. Who were you employed with at
22 that time?
23 A. It's called Eye in the Sky.
24 It's a camera company for security. I
25 worked with them, put the security
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2 hookup in houses or buildings, whatever.
3 They work for the fed building, DA
4 building. That's where we used to work
5 at, put the cameras, place the cameras
6 and security. Install fall panic
7 buttons.
8 Q. How long did you work for
9 them?
10 A. How long did I work for them,
11 three years.
12 Q. Where were you employed
13 before that?
14 A. I was working for Labor
15 Temps. I work for Labor Temps for like
16 twelve years, twelve to ten years.
17 Q. Before that?
18 A. Before that, it was Western
19 Beef. I guess I was with Western Beef
20 for four years.
21 Q. Why did you leave Eye in the
22 Sky?
23 A. Huh?
24 Q. Why did you leave Eye in the
25 Sky?
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2 A. The boss saw me hurt. I
3 couldn't climb up a ladder properly.
4 Ten years ago, I got robbed.
5 When I got robbed, I got two cracked
6 ribs and a cracked spine. That was in
7 the Bronx when I had to go collect money
8 for my mother and stuff like that. When
9 everything was okay, I thought it was
10 okay. That's when I got robbed over
11 there, I got -- had a cracked spine for
12 ten years.
13 Q. So you were no longer able to
14 perform the duties?
15 A. Yeah, at work.
16 Q. Merline McDowell is your
17 mother; correct?
18 A. Yes.
19 Q. Did she raise you?
20 A. Yes.
21 Q. Did she marry and divorce
22 Jack Francois [phonetic spelling]?
23 A. Yes.
24 Q. He is not your father?
25 A. No.
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2 Q. What's your father's name?
3 A. Victor Izquierdo.
4 Q. Is Jack Francois still alive?
5 A. No. He passed away. I'm
6 trying remember. Jack Francois passed
7 away in 1995, '94, '95, yeah -- not '94,
8 '98, '99. My mistake.
9 Q. Did he ever live at the
10 property and when --
11 A. For one year.
12 Q. -- when I say "the property",
13 you know what I'm talking about;
14 correct?
15 A. Yeah, for one year.
16 Q. What about Victor Izquierdo,
17 your father?
Preview
FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 EXHIBIT A FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 1 1 2 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF QUEENS 3 Index No.: 716943/2017 - - - - - - - - - - - - - - - - - - - -x 4 WELLS FARGO BANK, N.A., AS TRUSTEE, FOR THE CERTIFICATE HOLDERS OF MORGAN 5 STANLEY ABS CAPITAL I, INC., TRUST 2005-WMC, MORTGAGE PASS THROUGH 6 CERTIFICATES, SERIES 2005-WMC5, Plaintiff, 7 -against- 8 RONFAYZI INC., PEOPLE OF THE STATE OF NEW YORK, NEW YORK CITY ENVIRONMENTAL 9 CONTROL BOARD, NEW YORK CITY TRANSIT ADJUDICATION BOARD, NEW YORK CITY 10 DEPARTMENT OF FINANCE, JOHN DOE (Those unknown tenants, occupants, persons of 11 corporations or their heirs, distributees, executors, administrators, 12 trustees, guardians, assignees, creditors or successors claiming an 13 interest in the mortgaged premises), 14 Defendants. - - - - - - - - - - - - - - - - - - - -x 15 350 Fifth Avenue 16 New York, New York 17 January 16, 2019 11:34 a.m. 18 19 EXAMINATION BEFORE TRIAL of ALMANDO 20 IZQUIERDO a/k/a ALMANDO SEAN IZQUIERDO, 21 a witness, before Julia M. Callahan, a 22 Certified Court Reporter and Notary 23 Public of the State of New York. 24 25 Job No. CS3197153 Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 2 1 2 A P P E A R A N C E S: 3 4 FIDELITY NATIONAL LAW GROUP 5 350 Fifth Avenue Suite 3000 6 New York, New York 10118 7 Co-Counsel for Plaintiff 8 BY: TERENCE WATSON, ESQ. MARIANNE F. MURRAY, ESQ. 9 10 11 GROSS POLOWY, LLC 12 900 Merchants Concourse Suite 412 13 Westbury, New York 11590 14 Co-Counsel for Plaintiff 15 BY: LISA M. BRADLEY, ESQ. 16 17 ALSO PRESENT: Oliver Ness, Fordham 18 University Intern 19 20 * * * 21 22 23 24 25 Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 3 1 2 S T I P U L A T I O N S 3 4 IT IS HEREBY STIPULATED AND AGREED 5 by and between counsel for the 6 respective parties hereto, that: 7 All rights provided by the 8 C.P.L.R., and Part 221 Of the Uniform 9 Rules for the Conduct of Depositions, 10 including the right to object to any 11 question, except as to form, or to move 12 to strike any testimony at this 13 examination is reserved; and in 14 addition, the failure to object to any 15 question or to move to strike any 16 testimony at this examination shall not 17 be a bar or waiver to make such motion 18 at, and is reserved to, the trial of 19 this action. 20 This deposition may be sworn to by 21 the witness being examined before a 22 Notary Public other than the Notary 23 Public before whom this examination was 24 begun, but the failure to do so or to 25 return the original of this deposition Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 4 1 2 to counsel, shall not be deemed a waiver 3 of the rights provided by Rule 3116 of 4 the C.P.L.R., and shall be controlled 5 thereby. 6 The filing of the original of this 7 deposition is waived. 8 IT IS FURTHER STIPULATED, a copy of 9 this examination shall be furnished to 10 the attorney for the witness being 11 examined without charge. 12 13 * * * 14 15 16 17 18 19 20 21 22 23 24 25 Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 5 1 2 A L M A N D O S E A N 3 I Z Q U I E R D O, the witness herein, 4 having first been duly sworn by the 5 Notary Public, was examined and 6 testified as follows: 7 BY THE COURT REPORTER: 8 Q. Please state your name for 9 the record? 10 A. Almando Sean Izquierdo. 11 Q. Where do you reside? 12 A. 177-26 Ursina Road, 13 St. Albans, New York 11434. 14 EXAMINATION BY 15 MR. WATSON: 16 Good afternoon, 17 Mr. Izquierdo. My name is Terence 18 Watson. I'm co-counsel for the 19 plaintiff, Wells Fargo Bank verses 20 Ronfayzi and other parties in an 21 action currently pending in Queens 22 County. 23 Before we start today's 24 deposition, I would like to ask you 25 if you would like to adjourn the Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 6 1 ALMANDO SEAN IZQUIERDO 2 deposition, hold it on another date 3 to enable you to retain counsel to 4 represent you in connection with 5 the deposition? 6 THE WITNESS: No. 7 MR. WATSON: You would like 8 to proceed today -- 9 THE WITNESS: Yes. 10 MR. WATSON: -- without 11 counsel? 12 THE WITNESS: Yes. 13 MR. WATSON: Have you ever 14 been deposed before? 15 THE WITNESS: Um. 16 MR. WATSON: Sat for a 17 deposition? 18 THE WITNESS: No. This is 19 the first time ever. 20 MR. WATSON: You've never 21 testified in court or anything like 22 that as a witness? 23 THE WITNESS: No. 24 MR. WATSON: I'd just like to 25 go over some of the ground rules to Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 7 1 ALMANDO SEAN IZQUIERDO 2 make it easier technically for the 3 court reporter. 4 If you don't understand any 5 of my questions, please ask me to 6 rephrase it and I'll be happy to 7 rephrase it or repeat the question. 8 THE WITNESS: Okay. 9 MR. WATSON: For court the 10 reporter's sake, we have to talk 11 one at a time. Let me finish my 12 question. Even if you may think 13 you know what the question is going 14 to be, let me finish my question 15 before you answer. 16 THE WITNESS: Yes. 17 MR. WATSON: All your 18 responses have to be oral so she 19 can transcribe it, type it out. No 20 shaking of the head, nodding of the 21 head or things of that nature. 22 THE WITNESS: I'll try to be 23 very clear. 24 MR. WATSON: No shaking of 25 the head because the court reporter Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 8 1 ALMANDO SEAN IZQUIERDO 2 can't transcribe the information. 3 THE WITNESS: Yes. 4 MR. WATSON: If, at any time, 5 you want to take a break, let me 6 know you want to take a break. The 7 only thing I ask is not to request 8 the break when a question is 9 pending; is that okay? 10 THE WITNESS: Okay. 11 MR. WATSON: Did you take any 12 medication today that would prevent 13 you from either understanding my 14 questions today or answering the 15 questions truthfully? 16 THE WITNESS: Only thing I 17 take is pain medication for my 18 broken finger and my leg and my 19 back, yeah. 20 MR. WATSON: We are here for 21 your deposition today in connection 22 with the action that I described 23 before, Wells Fargo verses various 24 defendants, including yourself. 25 The index number 716943/2017. I'll Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 9 1 ALMANDO SEAN IZQUIERDO 2 refer to it as the action to speed 3 things up today, okay? 4 THE WITNESS: Okay. 5 MR. WATSON: I'll also refer 6 to your current home in St. Albans, 7 the address you just provided -- 8 THE WITNESS: Yes. 177-26 9 Ursina Road, St. Albans, New York 10 11434. 11 MR. WATSON: Right, 177-26 12 Ursina Road, St. Albans, I'll refer 13 to that as the property -- 14 THE WITNESS: Okay. 15 MR. WATSON: -- to sort of 16 speed things along. 17 THE WITNESS: Yes. 18 MR. WATSON: If I have 19 questions with respect to other 20 properties, I'll identify them by 21 the address. 22 THE WITNESS: Yes. 23 Q. Did you meet with anyone to 24 prepare for today's deposition? 25 A. No. Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 10 1 ALMANDO SEAN IZQUIERDO 2 Q. Did you review any documents 3 to prepare for today's deposition? 4 A. Yes. 5 Q. What documents did you 6 review? 7 A. Um -- he moved out, the time 8 he moved and he came back. 9 Q. I'm sorry, who? 10 A. Walter McDowell and he was 11 out, he moved out and he came back home. 12 He moved out in 1985 to get himself 13 together and 1994 that's when he came 14 back, but he was not really back. He 15 was in and out like four more years 16 later, 1998. That's when he 17 collectively [sic] moved in because his 18 son, his son, was in the system because 19 his mother kicked his son out and he go 20 get him and show his place, say that he 21 had a place to stay for his son. That's 22 how his son was residing there in 23 1980 -- no, in 1998. 24 Q. So when you said he moved in, 25 are you talking about Walter? Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 11 1 ALMANDO SEAN IZQUIERDO 2 A. Walter, Jr. 3 Q. Walter, Jr.? 4 A. Yeah. 5 Q. Walter McDowell, Jr.? 6 A. Yes. Walter McDowell's son, 7 he was troubled by the City in 1998 8 because his mother kicked him out, 9 kicked her son out when he was, he was, 10 like one, two to three years old and his 11 father, when he got him, brought him to 12 the house. That's when he's stayed in 13 1998. 14 Q. My question was, what 15 documents did you review to prepare for 16 today's deposition; did you review any 17 documents to prepare for the deposition 18 today? 19 A. I don't know what you mean by 20 "documents." 21 Q. Did you look at any documents 22 to prepare for the deposition? 23 A. Yeah, I looked at documents, 24 yes. 25 Q. Which documents? Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 12 1 ALMANDO SEAN IZQUIERDO 2 A. I was just looking at when he 3 was moving out, in and out my house and 4 I looked at certain documents that he 5 forged when he got the property. When 6 my mother got sick in 2000, he was 7 forging records in 2001, 2002. That's 8 when he started forging documents. 9 Q. Walter, Jr.? 10 A. Walter, Jr. 11 Q. Which documents are you 12 alleging he forged? 13 A. He forged power of attorney, 14 he forged power of attorney and the 15 deed, he put it in his name. He stole 16 that. 17 There was [sic] properties in 18 the Bronx on White Plains Road. She had 19 half a block on 228th. He liquified 20 that. Where'd the 4 and a half million 21 dollars come from? The half a block had 22 six stores, a building and parking lot 23 in the back. That was half a block. 24 Crotona and Tremont, he 25 liquified that too. 1944 Tremont Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 13 1 ALMANDO SEAN IZQUIERDO 2 Avenue, he liquified that too. 3 Q. We'll get to those properties 4 and the allegations of forgery. 5 Briefly describe your 6 education background? 7 A. I didn't graduate out of high 8 school. 9 Q. How far did you get in 10 school? 11 A. I got to 12th grade. I 12 didn't graduate. 13 Q. Are you currently employed? 14 A. No, not anymore. I'm on SSID 15 now. 16 Q. Since when? 17 A. I'm just off employment 18 August, this past August. 19 Q. Since August 2018? 20 A. Yes. 21 Q. Who were you employed with at 22 that time? 23 A. It's called Eye in the Sky. 24 It's a camera company for security. I 25 worked with them, put the security Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 14 1 ALMANDO SEAN IZQUIERDO 2 hookup in houses or buildings, whatever. 3 They work for the fed building, DA 4 building. That's where we used to work 5 at, put the cameras, place the cameras 6 and security. Install fall panic 7 buttons. 8 Q. How long did you work for 9 them? 10 A. How long did I work for them, 11 three years. 12 Q. Where were you employed 13 before that? 14 A. I was working for Labor 15 Temps. I work for Labor Temps for like 16 twelve years, twelve to ten years. 17 Q. Before that? 18 A. Before that, it was Western 19 Beef. I guess I was with Western Beef 20 for four years. 21 Q. Why did you leave Eye in the 22 Sky? 23 A. Huh? 24 Q. Why did you leave Eye in the 25 Sky? Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 15 1 ALMANDO SEAN IZQUIERDO 2 A. The boss saw me hurt. I 3 couldn't climb up a ladder properly. 4 Ten years ago, I got robbed. 5 When I got robbed, I got two cracked 6 ribs and a cracked spine. That was in 7 the Bronx when I had to go collect money 8 for my mother and stuff like that. When 9 everything was okay, I thought it was 10 okay. That's when I got robbed over 11 there, I got -- had a cracked spine for 12 ten years. 13 Q. So you were no longer able to 14 perform the duties? 15 A. Yeah, at work. 16 Q. Merline McDowell is your 17 mother; correct? 18 A. Yes. 19 Q. Did she raise you? 20 A. Yes. 21 Q. Did she marry and divorce 22 Jack Francois [phonetic spelling]? 23 A. Yes. 24 Q. He is not your father? 25 A. No. Veritext Legal Solutions 800-567-8658 973-410-4098 FILED: QUEENS COUNTY CLERK 12/22/2020 04:49 PM INDEX NO. 716943/2017 NYSCEF DOC. NO. 51 RECEIVED NYSCEF: 12/22/2020 Page 16 1 ALMANDO SEAN IZQUIERDO 2 Q. What's your father's name? 3 A. Victor Izquierdo. 4 Q. Is Jack Francois still alive? 5 A. No. He passed away. I'm 6 trying remember. Jack Francois passed 7 away in 1995, '94, '95, yeah -- not '94, 8 '98, '99. My mistake. 9 Q. Did he ever live at the 10 property and when -- 11 A. For one year. 12 Q. -- when I say "the property", 13 you know what I'm talking about; 14 correct? 15 A. Yeah, for one year. 16 Q. What about Victor Izquierdo, 17 your father?