Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
41
1 Zaharah Badrudin - Atty. Adang
2 A I requested copies of what was in my
3 father's bank account when he died.
4 Q I'm talking about the money market account
5 now.
on n I re es anyhg h
7 money market account.
8 Q How about the Bluebird Terrace account, did
9 you request copies of those from the bank?
10 A I don't think I did.
11 Q You just said you think you did.
12 A No. I requested what was in my dad's
13 personal bank accounts when he passed away.
14 Q He had a personal bank?
15 A Yes; at TD Bank. It had $60 or I think 16.
16 Q I stand corrected. I'm sorry.
17 So from 2007, I will use that as a start
18 date, when you took over management of the park,
19 until 2010, when you opened up the money market
20 account, cash deposits went into the Bluebird
21 Terrace account?
A think so but also when -- isn't a firm
22 I it
23 date.
24 Q That's the date you gave me.
25 A I said around.
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
42
1 Zaharah Badrudin - Atty. Adang
2 Q You are the witness. It's your testimony.
3 A Around.
4 Q Since 2010, from 2010 until the time that
5 the mobile home park was sold, cash deposits were
6 made into the Bluebird Terrace account and perhaps
7 the money Ittarket adcoünt, is-that-correct?
8 A And I paid bills directly.
9 Q I'm asking you about deposited now.
10 A Only deposited. I think those are the only
11 two. I could be wrong but I think those are the
12 only two.
13 Q In 2010, how much cash was deposited into
14 the money market account?
15 A I have no idea.
16 Q In addition.to cash that may have been
17 deposited from rental income, was there cash or
18 deposits from any other source into the money market
19 account?
20 A Yes.
21 Q Where did the cash come from?
22 A Well, our jobs we put into various accounts.
--
23 It could include the money market account. I think
24 Q I'm going to stop you there because I want
25 to clarify something.
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
43
1 Zaharah Badrudin - Atty. Adang
2 Income from your jobs you put into the money
3 market account?
4 A I think so.
5 Q But my guestion was cash. So did you
6 receive cash from your jobs?
7 A My mom sometimes did because she worked at
8 Price Chopper as a bagger; used to get cash at the
9 reception.
10 Q Would she give you that cash to deposit into
11 the money market account?
12 A Not always. Sometimes she did it herself.
13 Q So it would be either you or her depositing
14 cash into the money market account?
15 A Yeah.
16 Q And the cash that she deposited would be
17 from her employment at Price Chopper?
18 A Yes.
19 Q And the cash that you deposited into the
20 money market account would have been from rental
21 income from the mobile home park. Were there any
22 other sources of cash?
23 A Yes.
24 Q What were those?
25 A I did a lot of Craigslist selling of junk.
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
44
1 Zaharah Badrudin - Atty. Adang
2 Q What did you sell?
3 A Furniture, phones, my camera. Anything I
4 was tired of using I would sell.
5 Q Do you have any records of those sales?
6 A Not really because Craigslist deals in cash;
7 sold a lot-of tlTings. Ã lot ¯of ¯i51â és when they
8 left with all their junk, they left it inside the
9 mobile home park, protocol is to throw it away. I
10 would see what I could salvage, then I would sell
11 it.
12 Q When you received the cash from the
--
13 purchasers, is this correct, we are talking about
14 A Yes.
15 Q Were there any receipts exchanged at that
16 point?
17 A No.
18 Q You never gave a buyer of something that was
19 purchased on Craigslist a receipt?
20 A Maybe I did but not that I kept it.
21 Q Any other sources of cash that went into the
22 money market account in 2010?
23 A Cash. Not that I can think of right now.
24 Q Do you have an estimate as to how much cash
25 was deposited into the money market account in 2010?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
45
1 Zaharah Badrudin - At .
ty Adang
2 A No; I have no idea.
3 MR. ADANG: We are going to take a
4 break for five minutes.
5 (Brief recess.)
6 EXAMINATION
7 BY MR. ADANG:
8 Q In 2011, you were collecting rents for the
9 mobile home park as well?
10 A Yes.
11 Q Was your mother also involved in collecting
12 rents?
13 A Yes.
14 Q How about your sister?
15 A No.
16 Q In 2011, did you receive cash from any of
17 the tenants?
18 A Yes.
19 Q Where was the cash deposited?
20 A If it was deposited, it was either in the
21 Bluebird account or the money market account, I
22 think.
23 Q Do you recall how much was deposited into
24 the Bluebird account?
25 A In 2011?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
46
1 Zaharah Badrudin - Atty. Adang
2 Q Yes.
3 A No.
4 Q Do you have any idea as to how much was
5 deposited into the money market account?
6 A No.
7 Q Earlier you testified that you had a receipt
8 book that you carried in your car?
9 A Yes.
10 Q You did that beginning when?
11 A I don't remember.
12 Q Did you do it in 2007 when you took over the
13 operation of the park?
14 A No.
15 Q _How about in 2008?
16 A I don't think so.
17 Q When do you first recall having done that?
18 A I only recall buying a receipt book once so
19 I think I only used one book for all those years but
20 I'm not sure when I bought it.
21 Q And who had possession of that book while it
22 was in use?
23 A Whoever was driving the car. Whoever was in
24 the car. It was in the car.
25 Q Who is whomever?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
- 6832
(518) 587
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
47
1 Zaharah Badrudin - Atty. Adang
--
2 A It could be my mom, my sister, me. If we
3 gave Clark rides a lot. Anyone in the car. The
4 receipt book was there in the middle.
5 Q Whose car was it?
6 A I think it was Salimah's.
Q Wh re-15-tTaTre¯dëipt book now?
8 A I don't know.
9 Q Where was it the last time that you saw it?
10 A The last time I saw it, it was in the car.
11 Q When was the last time you saw it?
12 A When we still had the park.
13 Q Do you want to be a little more clear for
14 the record? When was it that you still had the
15 park?
16 A In 2014.
17 Q So you saw it in 2014?
18 A I think so.
19 Q You haven't seen it since?
20 A No.
21 Q Is it a document that you gave to Judge Hall
22 pursuant to his order?
23 A It's not a document.
24 Q Is it a paper or record that you gave to
25 Judge Hall?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
48
1 Zaharah Badrudin - Atty. Adang
2 A It's an empty book. It has no record on it.
3 Q Is it something that you gave to Judge Hall?
4 A I could have.
5 Q Is it something that was destroyed in the
6 flood?
7 A It couldn't have been because I saw it
8 afterwards.
9 Q It could not have been?
10 A Yes.
11 Q And the flood occurred in 2011?
12 A Or '12.
13 Q Or '12.
14 What did the flood consist of?
15 A We were not heating the bottom layer of our
16 house to save money. When it became lower than 40
17 degrees, the meter cracked so the Town of Queensbury
18 came and replaced the meter so everything on the
19 lower floor had to be thrown out.
20 Q How many floors?
21 A Two.
22 Q Is the lower floor at grade level?
23 A Yes.
24 Q It's not below grade?
25 A No; I don't think so.
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
49
1 Zaharah Badrudin - Atty. Adang
2 Q Well, you live there.
3 A Yeah, but sometimes it's a little uneven so
4 recollection is you walk --
my
5 Q Do you have a basement?
6 A No.
7 Q Did you make a claim on your insurance
8 company for the losses sustained in the flood?
9 A No; I didn't know about it at that time.
10 Q I'm asking, did you make a claim on your
11 insurance company as a result of the losses
12 sustained?
13 A I didn't know you could do that so no.
14 Q The answer is no.
15 A Okay.
16 Q Thank you.
17 Ms. Badrudin, I'm going to show you
18 Deposition 31 marked for identification. Can you
19 tell me what that is?
20 MR. ADANG: Off the record.
21 (An off-the-record discussion was had.)
22 Q Can you identify that for me please?
23 A It looks like the commercial account
24 statement.
25 Q In whose name is the account?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
- 6832
(518) 587
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
50
1 Zaharah Badrudin - Atty. Adang
2 A Mohamed K. Badrudin, Bluebird Terrace.
3 Q What bank is it?
4 A Citizens Bank.
5 Q What's the account number?
6 A 551009-980-7.
7 TM tEe ëst-¯df¯your knowledge, is that the
8 account where you deposited the receipts from the
9 rental income from the mobile home park?
10 A Sorry, can you repeat the question?
11 Q To the best of your knowledge, is that the
12 account where you deposited receipts from the rental
13 income from the mobile home park?
14 A Most of them; yes.
15 Q I want you to take a look at that document.
16 There are a number of pages.
17 A (Complying)
18 Q I will ask you some.pretty general
19 questions.
20 Do you recognize or is it a fair statement
21 that attached to the exhibit are what appear to be
22 copies of postal money orders and checks which
23 represent rental income from the operation of the
24 mobile home park?
25 A Can you repeat the question?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
- 6832
(518) 587
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
51
1 Zaharah Badrudin - Atty. Adang
2 (The pending question was read by
3 the reporter.)
4 A I don't understand that question. Does it
5 mean that all of it is or there is some in it?
6 Q Why don't you take a look at it and you can
tell of --
7 me, yes, some those
8 A Are some of them, yes. Some of them are.
9 Q To the extent that some of them are not, can
10 you identify the ones that are not?
11 A Sure.
12 Q Thank you.
13 A On page 6 we have a Staples and American
14 Airlines. Those are not.
15 Q Anything else?
16 A One second.
17 MS. S. BADRUDIN: Can you say for
18 certain all of these are Bluebird checks?
19 MR. ADANG: Off the record.
20 (An off-the-record discussion was had.)
21 Q I would like you to take a look at Exhibit
22 31. Do some of the checks and money orders
23 represent income that was received from the
24 operation of the mobile home park?
25 A Some of them do, yes.
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
- 6832
(518) 587
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
52
1 Zaharah Badrudin - Atty. Adang
2 Q Are there any cash in deposit tickets that
3 are in that document?
4 A I don't know.
5 Q I'm asking you to take a look at it and tell
6 me.
7 -r-dMD't-Yifow õi¾ I can tell looking at this.
8 Q I think you have to look at it, then I think
9 you can tell.
10 A Let me see.
11 Your question was about cash?
12 Q Yes, cash.
13 A I went through this. I don't see anything
14 about cash.
15 Q May I take a look?
16 A (Handing)
17 Q I want you to first identify the date on the
18 statement. I don't think we did that.
19 A January 27, 2011 to February 24, 2011.
20 Q Thank you.
21 A You have pointed out teller's cash in
22 ticket.
23 MR. ADANG: Off the record.
24 (An off-the-record discussion was had.)
25 Q Are there any other cash in tickets?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
-
(518) 587 6832
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
53
1 Zaharah Badrudin - Atty. Adang
2 A I see another one, teller's cash in ticket.
3 Q For how much?
4 A For 1,000.
5 Q You don't know what that represents either,
6 is that correct?
7 A No. I don't know if that's the only one. I
8 didn't check the whole thing.
9 MR. ADANG: Off the record.
10 (An off-the-record discussion was had.)
11 MR. ADANG: The witness is looking
12 at Deposition Exhibit Number 31.
13 Q I believe you identified a cash deposit of
14 $1,000, is that correct?
15 A That is what you showed me.
16 Q Is that on the exhibit?
17 A That is the one you pointed out.
18 Q Is that the one that you are observing?
19 A After your direction. I wouldn't have gone
20 there myself.
21 MR. ADANG: Off the record.
22 (An off-the-record discussion was had.)
23 MR. ADANG: Again, the witness has
24 identified a $1,000 deposit.
25 Q When was that made?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
54
1 Zaharah Badrudin - Atty. Adang
2 A This one here that you showed me is on
3 February 10, 2011.
4 Q Does the document that you are looking at
5 reflect the source of the cash?
6 A No.
7- --- Q Do you k-r+MW-f lit-the source ot-the dasE¯was?
8 A From February 10, 2011?
9 Q Do you know the source of the $1,000? Very,
10 very simple question.
11 A On this date, February 10, 2011?
12 Q Of course, that date.
13 A I don't remember.
14 Q Is there any other date we are talking
15 about?
16 A I'm not sure.
17 Q Apparently, you want to continue this.
18 A So I'm not sure where it came from.
19 Q Thank you.
20 I would like you to look to see if there are
21 any other cash deposits.
22 A I see one on February 18 of 2011 for $390.
23 Q That's reflected on a deposit ticket, is
24 that correct?
25 A Yes.
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
-
(518) 587 6832
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022
55
1 Zaharah Badrudin - Atty. Adang
2 Q Does that deposit ticket identify the source
3 of the cash?
4 A No.
5 Q Do you know what the source of the cash was?
6 A No.
7 Q Thank you.
8 I show you Deposition Exhibit 32 marked for
9 identification. Can you identify that?
10 A It's a commercial account statement for
11 February 25, 2011 to March 23, 2011.
12 Q That's the same account as in Deposition
13 Exhibit 31, is that correct?
14 A Yes.
15 Q What is the date again?
16 A February 25 to March 23, 2011.
17 Q Does that exhibit identify any cash
18 deposits?
19 A I'm looking.
20 Q Can you tell me which ones?
21 A I see one on March 15, 2010.
22 Q For how much?
23 A 1,450.
24 Q Does the deposit indicate a source of the
25 cash?
STEPHANIE
Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 41 1 Zaharah Badrudin - Atty. Adang 2 A I requested copies of what was in my 3 father's bank account when he died. 4 Q I'm talking about the money market account 5 now. on n I re es anyhg h 7 money market account. 8 Q How about the Bluebird Terrace account, did 9 you request copies of those from the bank? 10 A I don't think I did. 11 Q You just said you think you did. 12 A No. I requested what was in my dad's 13 personal bank accounts when he passed away. 14 Q He had a personal bank? 15 A Yes; at TD Bank. It had $60 or I think 16. 16 Q I stand corrected. I'm sorry. 17 So from 2007, I will use that as a start 18 date, when you took over management of the park, 19 until 2010, when you opened up the money market 20 account, cash deposits went into the Bluebird 21 Terrace account? A think so but also when -- isn't a firm 22 I it 23 date. 24 Q That's the date you gave me. 25 A I said around. STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 42 1 Zaharah Badrudin - Atty. Adang 2 Q You are the witness. It's your testimony. 3 A Around. 4 Q Since 2010, from 2010 until the time that 5 the mobile home park was sold, cash deposits were 6 made into the Bluebird Terrace account and perhaps 7 the money Ittarket adcoünt, is-that-correct? 8 A And I paid bills directly. 9 Q I'm asking you about deposited now. 10 A Only deposited. I think those are the only 11 two. I could be wrong but I think those are the 12 only two. 13 Q In 2010, how much cash was deposited into 14 the money market account? 15 A I have no idea. 16 Q In addition.to cash that may have been 17 deposited from rental income, was there cash or 18 deposits from any other source into the money market 19 account? 20 A Yes. 21 Q Where did the cash come from? 22 A Well, our jobs we put into various accounts. -- 23 It could include the money market account. I think 24 Q I'm going to stop you there because I want 25 to clarify something. STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 43 1 Zaharah Badrudin - Atty. Adang 2 Income from your jobs you put into the money 3 market account? 4 A I think so. 5 Q But my guestion was cash. So did you 6 receive cash from your jobs? 7 A My mom sometimes did because she worked at 8 Price Chopper as a bagger; used to get cash at the 9 reception. 10 Q Would she give you that cash to deposit into 11 the money market account? 12 A Not always. Sometimes she did it herself. 13 Q So it would be either you or her depositing 14 cash into the money market account? 15 A Yeah. 16 Q And the cash that she deposited would be 17 from her employment at Price Chopper? 18 A Yes. 19 Q And the cash that you deposited into the 20 money market account would have been from rental 21 income from the mobile home park. Were there any 22 other sources of cash? 23 A Yes. 24 Q What were those? 25 A I did a lot of Craigslist selling of junk. STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 44 1 Zaharah Badrudin - Atty. Adang 2 Q What did you sell? 3 A Furniture, phones, my camera. Anything I 4 was tired of using I would sell. 5 Q Do you have any records of those sales? 6 A Not really because Craigslist deals in cash; 7 sold a lot-of tlTings. Ã lot ¯of ¯i51â és when they 8 left with all their junk, they left it inside the 9 mobile home park, protocol is to throw it away. I 10 would see what I could salvage, then I would sell 11 it. 12 Q When you received the cash from the -- 13 purchasers, is this correct, we are talking about 14 A Yes. 15 Q Were there any receipts exchanged at that 16 point? 17 A No. 18 Q You never gave a buyer of something that was 19 purchased on Craigslist a receipt? 20 A Maybe I did but not that I kept it. 21 Q Any other sources of cash that went into the 22 money market account in 2010? 23 A Cash. Not that I can think of right now. 24 Q Do you have an estimate as to how much cash 25 was deposited into the money market account in 2010? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 45 1 Zaharah Badrudin - At . ty Adang 2 A No; I have no idea. 3 MR. ADANG: We are going to take a 4 break for five minutes. 5 (Brief recess.) 6 EXAMINATION 7 BY MR. ADANG: 8 Q In 2011, you were collecting rents for the 9 mobile home park as well? 10 A Yes. 11 Q Was your mother also involved in collecting 12 rents? 13 A Yes. 14 Q How about your sister? 15 A No. 16 Q In 2011, did you receive cash from any of 17 the tenants? 18 A Yes. 19 Q Where was the cash deposited? 20 A If it was deposited, it was either in the 21 Bluebird account or the money market account, I 22 think. 23 Q Do you recall how much was deposited into 24 the Bluebird account? 25 A In 2011? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 46 1 Zaharah Badrudin - Atty. Adang 2 Q Yes. 3 A No. 4 Q Do you have any idea as to how much was 5 deposited into the money market account? 6 A No. 7 Q Earlier you testified that you had a receipt 8 book that you carried in your car? 9 A Yes. 10 Q You did that beginning when? 11 A I don't remember. 12 Q Did you do it in 2007 when you took over the 13 operation of the park? 14 A No. 15 Q _How about in 2008? 16 A I don't think so. 17 Q When do you first recall having done that? 18 A I only recall buying a receipt book once so 19 I think I only used one book for all those years but 20 I'm not sure when I bought it. 21 Q And who had possession of that book while it 22 was in use? 23 A Whoever was driving the car. Whoever was in 24 the car. It was in the car. 25 Q Who is whomever? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - 6832 (518) 587 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 47 1 Zaharah Badrudin - Atty. Adang -- 2 A It could be my mom, my sister, me. If we 3 gave Clark rides a lot. Anyone in the car. The 4 receipt book was there in the middle. 5 Q Whose car was it? 6 A I think it was Salimah's. Q Wh re-15-tTaTre¯dëipt book now? 8 A I don't know. 9 Q Where was it the last time that you saw it? 10 A The last time I saw it, it was in the car. 11 Q When was the last time you saw it? 12 A When we still had the park. 13 Q Do you want to be a little more clear for 14 the record? When was it that you still had the 15 park? 16 A In 2014. 17 Q So you saw it in 2014? 18 A I think so. 19 Q You haven't seen it since? 20 A No. 21 Q Is it a document that you gave to Judge Hall 22 pursuant to his order? 23 A It's not a document. 24 Q Is it a paper or record that you gave to 25 Judge Hall? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 48 1 Zaharah Badrudin - Atty. Adang 2 A It's an empty book. It has no record on it. 3 Q Is it something that you gave to Judge Hall? 4 A I could have. 5 Q Is it something that was destroyed in the 6 flood? 7 A It couldn't have been because I saw it 8 afterwards. 9 Q It could not have been? 10 A Yes. 11 Q And the flood occurred in 2011? 12 A Or '12. 13 Q Or '12. 14 What did the flood consist of? 15 A We were not heating the bottom layer of our 16 house to save money. When it became lower than 40 17 degrees, the meter cracked so the Town of Queensbury 18 came and replaced the meter so everything on the 19 lower floor had to be thrown out. 20 Q How many floors? 21 A Two. 22 Q Is the lower floor at grade level? 23 A Yes. 24 Q It's not below grade? 25 A No; I don't think so. STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 49 1 Zaharah Badrudin - Atty. Adang 2 Q Well, you live there. 3 A Yeah, but sometimes it's a little uneven so 4 recollection is you walk -- my 5 Q Do you have a basement? 6 A No. 7 Q Did you make a claim on your insurance 8 company for the losses sustained in the flood? 9 A No; I didn't know about it at that time. 10 Q I'm asking, did you make a claim on your 11 insurance company as a result of the losses 12 sustained? 13 A I didn't know you could do that so no. 14 Q The answer is no. 15 A Okay. 16 Q Thank you. 17 Ms. Badrudin, I'm going to show you 18 Deposition 31 marked for identification. Can you 19 tell me what that is? 20 MR. ADANG: Off the record. 21 (An off-the-record discussion was had.) 22 Q Can you identify that for me please? 23 A It looks like the commercial account 24 statement. 25 Q In whose name is the account? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - 6832 (518) 587 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 50 1 Zaharah Badrudin - Atty. Adang 2 A Mohamed K. Badrudin, Bluebird Terrace. 3 Q What bank is it? 4 A Citizens Bank. 5 Q What's the account number? 6 A 551009-980-7. 7 TM tEe ëst-¯df¯your knowledge, is that the 8 account where you deposited the receipts from the 9 rental income from the mobile home park? 10 A Sorry, can you repeat the question? 11 Q To the best of your knowledge, is that the 12 account where you deposited receipts from the rental 13 income from the mobile home park? 14 A Most of them; yes. 15 Q I want you to take a look at that document. 16 There are a number of pages. 17 A (Complying) 18 Q I will ask you some.pretty general 19 questions. 20 Do you recognize or is it a fair statement 21 that attached to the exhibit are what appear to be 22 copies of postal money orders and checks which 23 represent rental income from the operation of the 24 mobile home park? 25 A Can you repeat the question? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - 6832 (518) 587 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 51 1 Zaharah Badrudin - Atty. Adang 2 (The pending question was read by 3 the reporter.) 4 A I don't understand that question. Does it 5 mean that all of it is or there is some in it? 6 Q Why don't you take a look at it and you can tell of -- 7 me, yes, some those 8 A Are some of them, yes. Some of them are. 9 Q To the extent that some of them are not, can 10 you identify the ones that are not? 11 A Sure. 12 Q Thank you. 13 A On page 6 we have a Staples and American 14 Airlines. Those are not. 15 Q Anything else? 16 A One second. 17 MS. S. BADRUDIN: Can you say for 18 certain all of these are Bluebird checks? 19 MR. ADANG: Off the record. 20 (An off-the-record discussion was had.) 21 Q I would like you to take a look at Exhibit 22 31. Do some of the checks and money orders 23 represent income that was received from the 24 operation of the mobile home park? 25 A Some of them do, yes. STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - 6832 (518) 587 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 52 1 Zaharah Badrudin - Atty. Adang 2 Q Are there any cash in deposit tickets that 3 are in that document? 4 A I don't know. 5 Q I'm asking you to take a look at it and tell 6 me. 7 -r-dMD't-Yifow õi¾ I can tell looking at this. 8 Q I think you have to look at it, then I think 9 you can tell. 10 A Let me see. 11 Your question was about cash? 12 Q Yes, cash. 13 A I went through this. I don't see anything 14 about cash. 15 Q May I take a look? 16 A (Handing) 17 Q I want you to first identify the date on the 18 statement. I don't think we did that. 19 A January 27, 2011 to February 24, 2011. 20 Q Thank you. 21 A You have pointed out teller's cash in 22 ticket. 23 MR. ADANG: Off the record. 24 (An off-the-record discussion was had.) 25 Q Are there any other cash in tickets? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - (518) 587 6832 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 53 1 Zaharah Badrudin - Atty. Adang 2 A I see another one, teller's cash in ticket. 3 Q For how much? 4 A For 1,000. 5 Q You don't know what that represents either, 6 is that correct? 7 A No. I don't know if that's the only one. I 8 didn't check the whole thing. 9 MR. ADANG: Off the record. 10 (An off-the-record discussion was had.) 11 MR. ADANG: The witness is looking 12 at Deposition Exhibit Number 31. 13 Q I believe you identified a cash deposit of 14 $1,000, is that correct? 15 A That is what you showed me. 16 Q Is that on the exhibit? 17 A That is the one you pointed out. 18 Q Is that the one that you are observing? 19 A After your direction. I wouldn't have gone 20 there myself. 21 MR. ADANG: Off the record. 22 (An off-the-record discussion was had.) 23 MR. ADANG: Again, the witness has 24 identified a $1,000 deposit. 25 Q When was that made? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 54 1 Zaharah Badrudin - Atty. Adang 2 A This one here that you showed me is on 3 February 10, 2011. 4 Q Does the document that you are looking at 5 reflect the source of the cash? 6 A No. 7- --- Q Do you k-r+MW-f lit-the source ot-the dasE¯was? 8 A From February 10, 2011? 9 Q Do you know the source of the $1,000? Very, 10 very simple question. 11 A On this date, February 10, 2011? 12 Q Of course, that date. 13 A I don't remember. 14 Q Is there any other date we are talking 15 about? 16 A I'm not sure. 17 Q Apparently, you want to continue this. 18 A So I'm not sure where it came from. 19 Q Thank you. 20 I would like you to look to see if there are 21 any other cash deposits. 22 A I see one on February 18 of 2011 for $390. 23 Q That's reflected on a deposit ticket, is 24 that correct? 25 A Yes. STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - (518) 587 6832 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 57 RECEIVED NYSCEF: 06/23/2022 55 1 Zaharah Badrudin - Atty. Adang 2 Q Does that deposit ticket identify the source 3 of the cash? 4 A No. 5 Q Do you know what the source of the cash was? 6 A No. 7 Q Thank you. 8 I show you Deposition Exhibit 32 marked for 9 identification. Can you identify that? 10 A It's a commercial account statement for 11 February 25, 2011 to March 23, 2011. 12 Q That's the same account as in Deposition 13 Exhibit 31, is that correct? 14 A Yes. 15 Q What is the date again? 16 A February 25 to March 23, 2011. 17 Q Does that exhibit identify any cash 18 deposits? 19 A I'm looking. 20 Q Can you tell me which ones? 21 A I see one on March 15, 2010. 22 Q For how much? 23 A 1,450. 24 Q Does the deposit indicate a source of the 25 cash? STEPHANIE