Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 06/23/2022
61
1 Zaharah Badrudin - Atty. Adang
2 income but they could be for other reasons.
3 Q Are there any cash transactions which are
4 reflected in that exhibit?
5 A I see one on May 7, 2011 for $1,060.
6 Q Does the deposit ticket reflect the source
7 of that cash?
8 A No.
9 Q Do you have any present recollection as to
10 what the source of that cash was?
11 A Yes. You just showed me something a little
12 while ago that had the same amount so that I
13 recognize the amount.
14 Q What is it?
15 A 1,060.
16 Q My question was the source of it. Do you
17 have any present recollection as to the source of
18 that cash?
19 A No; I couldn't say accurately.
20 Q I show you Deposition Exhibit 35. Can you
21 identify that please?
22 A It's a commercial account statement.
23 Q Same account?
24 A Looks like it.
25 Q What period?
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. 58 RECEIVED NYSCEF: 06/23/2022
62
1 Zaharah Badrudin - Atty. Adang
2 A May 25, 2011 through June 23, 2011.
3 Q Again, can you take a look at that and tell
4 me if the checks and money orders that are attached
5 to that document reflect rental income from the
6 mobile home park.
Some checks are missing.
8 Q The ones that appear in this document, do
9 they represent income from the operation of the
10 mobile home park?
11 A I couldn't say because there are deposit
12 slips. Not all the checks are on here.
13 Q I'm asking you the checks and the money
do represent --
14 orders, they
15 A Not all of them.
16 Q Which ones do not?
17 A There is one for $50 to Salimah which does
18 not look normal.
19 Q That's the only one?
20 A And from the ones here that are not missing,
21 yeah, I think.
22 MR. ADANG: Off the record.
23 (An off-the-record discussion was had.)
24 Q I have shown the witness Deposition Exhibit
25 36 for identification. Can you identify that for me
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. 58 RECEIVED NYSCEF: 06/23/2022
63
1 Zaharah Badrudin - Atty. Adang
2 please?
3 A Sure; it's a commercial account statement.
4 Q You want to tell me what account and what
5 dates?
6 A Sure. From June 24, 2011 to July 26, 2011
7 for the Mohamed Badrudin Bluebird business green
8 checking, 551009-980-7.
9 Q I will ask you to take a look at that and
10 can you identify if there are checks and/or money
11 orders representing income from the operation of the
12 mobile home park?
13 A Sure; most of them.
14 Q Are there any cash transactions in that
15 account?
16 A Yeah.
17 Q Can you tell me?
18 A There is one for Salimah K. Badrudin on
19 7/25/11 for 2,080.15.
20 Q Does the deposit ticket represent the source
21 of those funds?
22 A No, it doesn't.
23 Q Do you have any independent recollection as
24 to what the source of funds is?
25 A No. There is other cash, it's from Mohamed
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. 58 RECEIVED NYSCEF: 06/23/2022
64
1 Zaharah Badrudin - Atty. Adang
2 Badrudin on 7/23/11.
3 Q What's the amount?
4 A $75.
5 Q Does the deposit ticket represent the source
6 of the cash?
7 A No.
8 Q Do you have any recollection as to the
9 source of that?
10 A I'm not sure why it says my dad's name.
--
11 Q My question was
12 (The requested portion of the record
13 was read back.)
14 A I did not deposit. My deceased father did
15 so no.
16 Q So the answer is no, you do not have any
17 recollection as to the source of it?
18 A No, I don't know where that came from.
19 Q The answer is, "no, I do not have a
20 recollection.
21 A Okay.
22 Q Thank you.
23 MR. ADANG: I'm showing the witness
24 Deposition Exhibit 37 for identification.
25 Q Can you identify that document?
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. 58 RECEIVED NYSCEF: 06/23/2022
65
1 Zaharah Badrudin - Atty. Adang
2 A It's a commercial account statement.
3 Q I think just for purposes of moving this
4 along, if you can just say it's for the same account
5 and tell me what the dates are. Okay?
6 A It's for July 27, 2011 through August 23,
for-
7 2011 locik-s--ITk-
¯thhamTaccount.
8 Q I will ask you to take a look at the
9 documents that are attached to that and tell me if
10 there are copies of checks or money orders
11 representing income from the operation of the mobile
12 home park.
13 A This one also is incomplete. It's missing.
14 Q Could you repeat that?
15 A There are copies in here that represent the
16 rental income.
17 Q Is there any cash deposit reflected in that
18 document?
19 A There is one on August 1, 2011 for $1,450.
20 Q Does the deposit ticket reflect the source
21 of that cash?
22 A I'm sorry, what was the question?
23 (The pending question was read by
24 the reporter.)
25 A No, it doesn't.
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. 58 RECEIVED NYSCEF: 06/23/2022
66
1 Zaharah Badrudin - At .
ty Adang
2 Q Do you have any recollection as to the
3 source of the cash?
4 A I do not.
5 Q Thank you.
6 Do you recall having seen Deposition Exhibit
7 37 previous to your testimony here today?
8 A No.
9 MR. ADANG: I'm showing the witness
10 Deposition Exhibit 38 for identification.
11 Q Can you identify that for me?
12 A Commercial account statement beginning
13 August 24, 2011 through September 26, 2011.
14 Q Same account?
15 A Yes.
16 Q I will ask you to look at that and, again,
17 tell me if the copies of checks and/or money orders
18 represent income from the operation of the mobile
19 home park for that period.
20 A Not all of them.
21 Q Tell me the ones that do not.
22 A There is this page here with Staples and
23 State University of New York and Citizens Bank that
24 don't. But there are also some deposit slips not
25 matching to the checks so it's incomplete.
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. 58 RECEIVED NYSCEF: 06/23/2022
67
1 Zaharah Badrudin - Atty. Adang
2 Q Does the document reflect any cash deposits?
3 A I see one here for 5,000 on September 21,
4 2011.
5 Q Does the deposit ticket indicate the source
6 of that cash?
.
7 ------A---No.
8 Q Do you have any recollection as to what the
9 source of the cash was?
10 A No. I wasn't the one that deposited it.
11 MR. ADANG: Move to strike that as
12 being non-responsive.
13 Q I'm going to ask you to stop and answer the
14 question. Please do not volunteer any information
15 because, otherwise, this is going to take an
16 inordinate period of t-ime to complete this. Your
17 volunteering information is not helping anything.
18 A Okay.
19 Q Are there any other cash deposits?
20 A Talking about the same one, the 5,000.
21 Q I think you answered my question.
22 A You striked my answer.
23 Q Is there any other cash other than the
24 5,000?
25 A Okay. Yes, there is another one deposited
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. 58 RECEIVED NYSCEF: 06/23/2022
68
1 Zaharah Badrudin - Atty. Adang
2 by Yasmin Badrudin on September 8, 2011 for $600.
3 Q Does the deposit ticket indicate the source
4 of the cash?
5 A No.
6 Q Do you have any recollection as to the
7 source of the cash?
8 A No.
9 Q Thank you.
10 MR. ADANG: I'm showing the witness
11 Deposition Exhibit 39 for identification.
12 Q Can you identify that for me?
13 A It's a commercial account statement
14 beginning September 27, 2011 through October 26,
15 2011. Looks like the same account.
16 Q Do the copies of the checks and/or money
17 orders represent rental payments from the operation
18 of the mobile home park?
19 A Not all of them.
20 Q Any that strike you as not being rental
21 income?
22 A Yes; one from Brennan & White, LLP, Escrow
23 Account.
24 Q For how much?
25 . A 800.
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. 58 RECEIVED NYSCEF: 06/23/2022
69
1 Zaharah Badrudin - .
Atty Adang
2 Q What about the remaining checks and money
3 orders?
4 A They could be from the rental income.
5 Q They could be?
6 A Yes.
7 Q You can't specifically say that they are?
8 A I can say they came from people that lived
9 there.
10 Q Are there any cash deposits reflected in the
11 document?
12 A There is one on October 5, 2011 deposited by
13 Y. Badrudin for 1,050.
14 Q Does the deposit ticket reflect the source
15 of that?
16 A No.
17 Q Do you have any knowledge as to the source
18 of it?
19 A No.
20 Q Any others?
21 A There is another one on October 15, 2011
22 deposited by Y. Badrudin for 1,620.
23 Q Does the deposit ticket reflect the source?
24 A No.
25 Q Do you have any independent recollection as
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. 58 RECEIVED NYSCEF: 06/23/2022
70
1 Zaharah Badrudin - Atty. Adang
2 to the source?
3 A No.
4 Q Thank you.
5 I show you Deposition Exhibit 40. Can you
6 identify that please.
7 A It's a commercial account statement
8 beginning October 27, 2011 through November 25, 2011
9 for what looks like the same account.
10 Q Can you tell me if the checks or money
11 orders represent rental income from the operation of
12 the mobile home park?
13 A There are some that do.
14 Q Any cash deposits reflected?
15 A I don't see any.
16 Q Thank you.
17 I show you Deposition Exhibit 41 marked for
18 identification. Can you identify that?
19 A Sure. It's the commercial account statement
20 beginning November 26, 2011 through December 23,
21 2011 for what looks like to be the same account.
22 Q Are the checks and money orders you see
23 attached to that, are there any that do not appear,
24 in your opinion, to be rental income from the
25 operation of the mobile home park?
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. 58 RECEIVED NYSCEF: 06/23/2022
71
1 Zaharah Badrudin - †tty. Adang
2 A There is from the State University of New
3 York.
4 Q How much?
5 A Looks like together $5,334.
6 Q What does that represent, do you know?
7 A It looks like it's from the school we
8 attended.
9 Q Who is it made payable to?
10 A To me.
11 Q For how much?
12 A $5,334.05.
13 Q That's from the school you attended?
14 A Yes.
15 Q What school is that?
16 A Looks like Empire State College.
17 Q Did that represent a refund of something?
18 A It may have been. It may have been. I also
19 took a loan. I also had a scholarship. So I'm not
20 sure which one it is.
21 Q If it was a scholarship, they would give you
22 cash?
23 A They could. I think they gave me more than
24 how much the tuition was.
25 Q That's for how much?
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. 58 RECEIVED NYSCEF: 06/23/2022
72
1 Zaharah Badrudin - Atty. Adang
2 A $5,334.
3 Q How about any other checks or money orders
4 in that exhibit not attributable to income from the
5 operation of the park?
6 A I couldn't say they are all attributed to
7 the income from the park. I would say some of these
8 are.
9 Q My question was, are there any that are not?
10 A There could be. I'm not sure.
11 Tell me --
Q
12 A I'm not sure. All of these doesn't
13 specifically say it's for rent. Most of them.
14 MR. ADANG: Off the record.
15 (An off-the-record discussion was had.)
16 Q Can you tell me if there are any cash
17 deposits?
18 A There is one on December 3, 2011 for $700.
19 Q Can you tell me what the source or does the
20 deposit ticket reflect the source of that?
21 A No.
22 Q Do you have any independent recollection as
23 to the source?
24 A No.
25 Q How about any other cash deposits?
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. 58 RECEIVED NYSCEF: 06/23/2022
73
1 Zaharah Badrudin - †tty. Adang
2 A One on December 5, 2011 for $1,300.
3 Q Does the deposit ticket reflect the source?
4 A No.
5 Q Do you have any independent recollection as
6 to the source?
7 A No.
8 Q Any additional?
9 A There is one December 5, 2011 for $1,000.
10 Q Does the deposit ticket reflect the source?
11 A No.
12 Q Do you have any independent recollection as
13 to the source?
14 A No.
15 Q Any others?
16 A No.
17 Q I want you to take a look at it again. Is
18 there one for $655 on December 3?
19 A Yes.
20 Q Does the deposit ticket reflect the source
21 of that cash?
22 A No.
23 Q Do you have any independent recollection as
24 to the source?
25 A No.
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. 58 RECEIVED NYSCEF: 06/23/2022
74
1 Zaharah Badrudin - Atty. Adang
2 Q Thank you.
3 MR. ADANG: I think we will take a
4 break.
5 (Luncheon recess.)
6 ZAHARAH BADRUDIN, called as a
7 witness, having been re-sworn, testified as
8 follows:
9 EXAMINATION
10 BY MR. ADANG:
11 Q I have shown you Deposition Exhibit Number
12 42. Can you identify that for me please?
13 A It reads commercial account statement
14 beginning December 24, 2011 through January 26,
15 2012.
16 Q That's the same account as the other
17 exhibits that you previously identified?
18 A It looks like that; yes.
19 Q Are there any cash deposits in that,
20 reflected in that exhibit?
21 A There is one on December 30, 2011 for $550.
22 Q Does the deposit ticket reflect the source
23 of the cash?
24 A No.
25 Q Do you have any independent recollection as
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. 58 RECEIVED NYSCEF: 06/23/2022
75
1 Zaharah Badrudin - Atty. Adang
2 to the source of the cash?
3 A It looks like rent.
4 Q Do you have any independent recollection as
5 to the source of it?
6 A I would say it looks like rent.
7 Q Thank you.
8 I have shown the witness Deposition Exhibit
9 43. Can you identify that for me please?
10 A Reads commercial account statement beginning
11 January 27, 2012 through February 24, 2012. Looks
12 like the same account.
13 Q Does this exhibit reflect any cash deposits?
14 A Yes; on February 2, 2012 there is a deposit
15 by Y. Badrudin for $380.
16 Q Does the deposit ticket reflect the source?
17 A No.
18 Q Do you have any independent recollection as
19 to the source?
20 A No.
21 On February 6, 2012, Y. Badrudin deposited
22 $3,000.
23 Q Does the deposit ticket reflect the source
24 of the cash?
25 A No.
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. 58 RECEIVED NYSCEF: 06/23/2022
Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 58 RECEIVED NYSCEF: 06/23/2022 61 1 Zaharah Badrudin - Atty. Adang 2 income but they could be for other reasons. 3 Q Are there any cash transactions which are 4 reflected in that exhibit? 5 A I see one on May 7, 2011 for $1,060. 6 Q Does the deposit ticket reflect the source 7 of that cash? 8 A No. 9 Q Do you have any present recollection as to 10 what the source of that cash was? 11 A Yes. You just showed me something a little 12 while ago that had the same amount so that I 13 recognize the amount. 14 Q What is it? 15 A 1,060. 16 Q My question was the source of it. Do you 17 have any present recollection as to the source of 18 that cash? 19 A No; I couldn't say accurately. 20 Q I show you Deposition Exhibit 35. Can you 21 identify that please? 22 A It's a commercial account statement. 23 Q Same account? 24 A Looks like it. 25 Q What period? 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. 58 RECEIVED NYSCEF: 06/23/2022 62 1 Zaharah Badrudin - Atty. Adang 2 A May 25, 2011 through June 23, 2011. 3 Q Again, can you take a look at that and tell 4 me if the checks and money orders that are attached 5 to that document reflect rental income from the 6 mobile home park. Some checks are missing. 8 Q The ones that appear in this document, do 9 they represent income from the operation of the 10 mobile home park? 11 A I couldn't say because there are deposit 12 slips. Not all the checks are on here. 13 Q I'm asking you the checks and the money do represent -- 14 orders, they 15 A Not all of them. 16 Q Which ones do not? 17 A There is one for $50 to Salimah which does 18 not look normal. 19 Q That's the only one? 20 A And from the ones here that are not missing, 21 yeah, I think. 22 MR. ADANG: Off the record. 23 (An off-the-record discussion was had.) 24 Q I have shown the witness Deposition Exhibit 25 36 for identification. Can you identify that for me 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. 58 RECEIVED NYSCEF: 06/23/2022 63 1 Zaharah Badrudin - Atty. Adang 2 please? 3 A Sure; it's a commercial account statement. 4 Q You want to tell me what account and what 5 dates? 6 A Sure. From June 24, 2011 to July 26, 2011 7 for the Mohamed Badrudin Bluebird business green 8 checking, 551009-980-7. 9 Q I will ask you to take a look at that and 10 can you identify if there are checks and/or money 11 orders representing income from the operation of the 12 mobile home park? 13 A Sure; most of them. 14 Q Are there any cash transactions in that 15 account? 16 A Yeah. 17 Q Can you tell me? 18 A There is one for Salimah K. Badrudin on 19 7/25/11 for 2,080.15. 20 Q Does the deposit ticket represent the source 21 of those funds? 22 A No, it doesn't. 23 Q Do you have any independent recollection as 24 to what the source of funds is? 25 A No. There is other cash, it's from Mohamed 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. 58 RECEIVED NYSCEF: 06/23/2022 64 1 Zaharah Badrudin - Atty. Adang 2 Badrudin on 7/23/11. 3 Q What's the amount? 4 A $75. 5 Q Does the deposit ticket represent the source 6 of the cash? 7 A No. 8 Q Do you have any recollection as to the 9 source of that? 10 A I'm not sure why it says my dad's name. -- 11 Q My question was 12 (The requested portion of the record 13 was read back.) 14 A I did not deposit. My deceased father did 15 so no. 16 Q So the answer is no, you do not have any 17 recollection as to the source of it? 18 A No, I don't know where that came from. 19 Q The answer is, "no, I do not have a 20 recollection. 21 A Okay. 22 Q Thank you. 23 MR. ADANG: I'm showing the witness 24 Deposition Exhibit 37 for identification. 25 Q Can you identify that document? 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. 58 RECEIVED NYSCEF: 06/23/2022 65 1 Zaharah Badrudin - Atty. Adang 2 A It's a commercial account statement. 3 Q I think just for purposes of moving this 4 along, if you can just say it's for the same account 5 and tell me what the dates are. Okay? 6 A It's for July 27, 2011 through August 23, for- 7 2011 locik-s--ITk- ¯thhamTaccount. 8 Q I will ask you to take a look at the 9 documents that are attached to that and tell me if 10 there are copies of checks or money orders 11 representing income from the operation of the mobile 12 home park. 13 A This one also is incomplete. It's missing. 14 Q Could you repeat that? 15 A There are copies in here that represent the 16 rental income. 17 Q Is there any cash deposit reflected in that 18 document? 19 A There is one on August 1, 2011 for $1,450. 20 Q Does the deposit ticket reflect the source 21 of that cash? 22 A I'm sorry, what was the question? 23 (The pending question was read by 24 the reporter.) 25 A No, it doesn't. 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. 58 RECEIVED NYSCEF: 06/23/2022 66 1 Zaharah Badrudin - At . ty Adang 2 Q Do you have any recollection as to the 3 source of the cash? 4 A I do not. 5 Q Thank you. 6 Do you recall having seen Deposition Exhibit 7 37 previous to your testimony here today? 8 A No. 9 MR. ADANG: I'm showing the witness 10 Deposition Exhibit 38 for identification. 11 Q Can you identify that for me? 12 A Commercial account statement beginning 13 August 24, 2011 through September 26, 2011. 14 Q Same account? 15 A Yes. 16 Q I will ask you to look at that and, again, 17 tell me if the copies of checks and/or money orders 18 represent income from the operation of the mobile 19 home park for that period. 20 A Not all of them. 21 Q Tell me the ones that do not. 22 A There is this page here with Staples and 23 State University of New York and Citizens Bank that 24 don't. But there are also some deposit slips not 25 matching to the checks so it's incomplete. 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. 58 RECEIVED NYSCEF: 06/23/2022 67 1 Zaharah Badrudin - Atty. Adang 2 Q Does the document reflect any cash deposits? 3 A I see one here for 5,000 on September 21, 4 2011. 5 Q Does the deposit ticket indicate the source 6 of that cash? . 7 ------A---No. 8 Q Do you have any recollection as to what the 9 source of the cash was? 10 A No. I wasn't the one that deposited it. 11 MR. ADANG: Move to strike that as 12 being non-responsive. 13 Q I'm going to ask you to stop and answer the 14 question. Please do not volunteer any information 15 because, otherwise, this is going to take an 16 inordinate period of t-ime to complete this. Your 17 volunteering information is not helping anything. 18 A Okay. 19 Q Are there any other cash deposits? 20 A Talking about the same one, the 5,000. 21 Q I think you answered my question. 22 A You striked my answer. 23 Q Is there any other cash other than the 24 5,000? 25 A Okay. Yes, there is another one deposited 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. 58 RECEIVED NYSCEF: 06/23/2022 68 1 Zaharah Badrudin - Atty. Adang 2 by Yasmin Badrudin on September 8, 2011 for $600. 3 Q Does the deposit ticket indicate the source 4 of the cash? 5 A No. 6 Q Do you have any recollection as to the 7 source of the cash? 8 A No. 9 Q Thank you. 10 MR. ADANG: I'm showing the witness 11 Deposition Exhibit 39 for identification. 12 Q Can you identify that for me? 13 A It's a commercial account statement 14 beginning September 27, 2011 through October 26, 15 2011. Looks like the same account. 16 Q Do the copies of the checks and/or money 17 orders represent rental payments from the operation 18 of the mobile home park? 19 A Not all of them. 20 Q Any that strike you as not being rental 21 income? 22 A Yes; one from Brennan & White, LLP, Escrow 23 Account. 24 Q For how much? 25 . A 800. 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. 58 RECEIVED NYSCEF: 06/23/2022 69 1 Zaharah Badrudin - . Atty Adang 2 Q What about the remaining checks and money 3 orders? 4 A They could be from the rental income. 5 Q They could be? 6 A Yes. 7 Q You can't specifically say that they are? 8 A I can say they came from people that lived 9 there. 10 Q Are there any cash deposits reflected in the 11 document? 12 A There is one on October 5, 2011 deposited by 13 Y. Badrudin for 1,050. 14 Q Does the deposit ticket reflect the source 15 of that? 16 A No. 17 Q Do you have any knowledge as to the source 18 of it? 19 A No. 20 Q Any others? 21 A There is another one on October 15, 2011 22 deposited by Y. Badrudin for 1,620. 23 Q Does the deposit ticket reflect the source? 24 A No. 25 Q Do you have any independent recollection as 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. 58 RECEIVED NYSCEF: 06/23/2022 70 1 Zaharah Badrudin - Atty. Adang 2 to the source? 3 A No. 4 Q Thank you. 5 I show you Deposition Exhibit 40. Can you 6 identify that please. 7 A It's a commercial account statement 8 beginning October 27, 2011 through November 25, 2011 9 for what looks like the same account. 10 Q Can you tell me if the checks or money 11 orders represent rental income from the operation of 12 the mobile home park? 13 A There are some that do. 14 Q Any cash deposits reflected? 15 A I don't see any. 16 Q Thank you. 17 I show you Deposition Exhibit 41 marked for 18 identification. Can you identify that? 19 A Sure. It's the commercial account statement 20 beginning November 26, 2011 through December 23, 21 2011 for what looks like to be the same account. 22 Q Are the checks and money orders you see 23 attached to that, are there any that do not appear, 24 in your opinion, to be rental income from the 25 operation of the mobile home park? 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. 58 RECEIVED NYSCEF: 06/23/2022 71 1 Zaharah Badrudin - †tty. Adang 2 A There is from the State University of New 3 York. 4 Q How much? 5 A Looks like together $5,334. 6 Q What does that represent, do you know? 7 A It looks like it's from the school we 8 attended. 9 Q Who is it made payable to? 10 A To me. 11 Q For how much? 12 A $5,334.05. 13 Q That's from the school you attended? 14 A Yes. 15 Q What school is that? 16 A Looks like Empire State College. 17 Q Did that represent a refund of something? 18 A It may have been. It may have been. I also 19 took a loan. I also had a scholarship. So I'm not 20 sure which one it is. 21 Q If it was a scholarship, they would give you 22 cash? 23 A They could. I think they gave me more than 24 how much the tuition was. 25 Q That's for how much? 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. 58 RECEIVED NYSCEF: 06/23/2022 72 1 Zaharah Badrudin - Atty. Adang 2 A $5,334. 3 Q How about any other checks or money orders 4 in that exhibit not attributable to income from the 5 operation of the park? 6 A I couldn't say they are all attributed to 7 the income from the park. I would say some of these 8 are. 9 Q My question was, are there any that are not? 10 A There could be. I'm not sure. 11 Tell me -- Q 12 A I'm not sure. All of these doesn't 13 specifically say it's for rent. Most of them. 14 MR. ADANG: Off the record. 15 (An off-the-record discussion was had.) 16 Q Can you tell me if there are any cash 17 deposits? 18 A There is one on December 3, 2011 for $700. 19 Q Can you tell me what the source or does the 20 deposit ticket reflect the source of that? 21 A No. 22 Q Do you have any independent recollection as 23 to the source? 24 A No. 25 Q How about any other cash deposits? 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. 58 RECEIVED NYSCEF: 06/23/2022 73 1 Zaharah Badrudin - †tty. Adang 2 A One on December 5, 2011 for $1,300. 3 Q Does the deposit ticket reflect the source? 4 A No. 5 Q Do you have any independent recollection as 6 to the source? 7 A No. 8 Q Any additional? 9 A There is one December 5, 2011 for $1,000. 10 Q Does the deposit ticket reflect the source? 11 A No. 12 Q Do you have any independent recollection as 13 to the source? 14 A No. 15 Q Any others? 16 A No. 17 Q I want you to take a look at it again. Is 18 there one for $655 on December 3? 19 A Yes. 20 Q Does the deposit ticket reflect the source 21 of that cash? 22 A No. 23 Q Do you have any independent recollection as 24 to the source? 25 A No. 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. 58 RECEIVED NYSCEF: 06/23/2022 74 1 Zaharah Badrudin - Atty. Adang 2 Q Thank you. 3 MR. ADANG: I think we will take a 4 break. 5 (Luncheon recess.) 6 ZAHARAH BADRUDIN, called as a 7 witness, having been re-sworn, testified as 8 follows: 9 EXAMINATION 10 BY MR. ADANG: 11 Q I have shown you Deposition Exhibit Number 12 42. Can you identify that for me please? 13 A It reads commercial account statement 14 beginning December 24, 2011 through January 26, 15 2012. 16 Q That's the same account as the other 17 exhibits that you previously identified? 18 A It looks like that; yes. 19 Q Are there any cash deposits in that, 20 reflected in that exhibit? 21 A There is one on December 30, 2011 for $550. 22 Q Does the deposit ticket reflect the source 23 of the cash? 24 A No. 25 Q Do you have any independent recollection as 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. 58 RECEIVED NYSCEF: 06/23/2022 75 1 Zaharah Badrudin - Atty. Adang 2 to the source of the cash? 3 A It looks like rent. 4 Q Do you have any independent recollection as 5 to the source of it? 6 A I would say it looks like rent. 7 Q Thank you. 8 I have shown the witness Deposition Exhibit 9 43. Can you identify that for me please? 10 A Reads commercial account statement beginning 11 January 27, 2012 through February 24, 2012. Looks 12 like the same account. 13 Q Does this exhibit reflect any cash deposits? 14 A Yes; on February 2, 2012 there is a deposit 15 by Y. Badrudin for $380. 16 Q Does the deposit ticket reflect the source? 17 A No. 18 Q Do you have any independent recollection as 19 to the source? 20 A No. 21 On February 6, 2012, Y. Badrudin deposited 22 $3,000. 23 Q Does the deposit ticket reflect the source 24 of the cash? 25 A No. 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. 58 RECEIVED NYSCEF: 06/23/2022