Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/23/2022
101
1 Zaharah Badrudin - Atty. Adang
2 A Okay. I couldn't --
say
3 MR. ADANG: Off the record.
4 (An off-the-record discussion was had.)
5 A Now I can't say I for sure told them. You
6 can compel.
7 Q You testified so what is the name?
8 A I would like to change my testimony. I'm
9 not sure if I told them. I know I spoke to family
10 members. I can't say which ones specifically.
11 Q You are not sure you spoke to the lawyer
12 cousin that you are not sure that you spoke to?
13 A I'm not disclosing that. You can compel me
14 like you said you would.
15 Q I'm just going to ask the judge to compel
16 you to answer that question.
17 A Please.
18 Q Who else did you speak with?
19 A People I knew at the time. I couldn't say
20 their names. I couldn't remember if I spoke to them
21 or not.
22 Q So you spoke to people but you can't
23 remember the name or names of anybody that you spoke
24 to?
25 A The reason is because I spoke to so many
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. 60 RECEIVED NYSCEF: 06/23/2022
102
1 Zaharah Badrudin - Atty. Adang
2 people, I couldn't say I spoke definitively to this
3 person or I didn't speak definitively to this
4 person. I know I was trying to get information
5 everywhere I possibly could including talking to
6 attorneys in the phonebook for free consults as well
7 as Google search.
8 Q What attorneys did you consult with?
9 A I didn't keep a record of that. I don't
10 know them so I don't know their names.
11 Q You called an attorney or attorneys and
12 spoke to them?
13 A Yeah.
14 Q You can't remember any names?
15 A I called a lot of them.
16 Q Without being specific as to whom you spoke
17 to, what were you told?
18 A That I had to record it.
19 Q And what else were you told?
20 A That as soon as the deed was delivered to my
21 mom, that she was the owner of the property.
22 Q By whom?
23 A I don't remember their names.
24 Q You were told by someone that as soon as the
25 deed was delivered to your mother, she was the owner
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. 60 RECEIVED NYSCEF: 06/23/2022
103
1 Zaharah Badrudin - Atty. Adang
2 of the property?
3 A Yes.
4 Q At the time that you discovered the deeds,
5 was your father's estate proceeding pending in
6 Warren County Surrogate's Court?
7 A Yes.
8 Q Who was the representative of the estate at
9 that time?
10 A My mom.
11 Q Did you notify the Surrogate's Court
12 independently that you had located the deed or
13 deeds?
14 A No.
15 Q Do you know if your mother notified the
16 Surrogate's Court of the acquisition of these deeds?
17 A I don't think we spoke to the Court directly
18 so I don't think any of us.
19 Q Who did you speak to if not the Court
20 directly?
21 A We would have spoken to our attorney.
22 Q Did you speak to your attorney?
23 A I don't think so.
24 Q Did you have an attorney?
25 A I think so.
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. 60 RECEIVED NYSCEF: 06/23/2022
104
1 Zaharah Badrudin - Atty. Adang
2 Q Who was your attorney?
3 A Brad Krause.
4 Q He was your attorney or the estate attorney?
5 A I don't know this distinction.
6 Q So you told Mr. Krause?
7 A Yes.
8 Q Or Mr. Krause was told?
--
9 A No, no. I wasn't like I said, I'm not
10 sure if I told him.
11 Q Do you have any independent knowledge that
12 your mother told Mr. Krause?
13 A No.
14 Q Do you have any independent knowledge that
15 your sister told Mr. Krause?
16 A I wouldn't know.
17 Q You wouldn't know or you don't have any
18 independent knowledge?
19 A I wouldn't know if either of them told.
20 Q After you discovered the deeds with your
21 sister, did you deliver them to the possession of
22 your mother?
23 A No.
24 Q What did you do with them?
25 A After asking all these people, I think we
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. 60 RECEIVED NYSCEF: 06/23/2022
105
1 saharah Badrudin - Atty. Adang
2 created deeds going from my mother to my sister.
3 Q When did you do that?
4 A I don't know the date.
5 Q Why was that done?
6 A Because that's what my mom wanted to do.
7 Q What was the reason that your mom wanted to
8 do that?
9 A Because since my dad's death was such a
10 shock and my mom's health was never good, we didn't
11 want anything to happen to my mom and have to go
12 through more proceedings, I think. But I can't be
13 sure. That's what I thought it was. But I don't
14 think she told me that directly because I'm guessing
15 to what she is thinking basically.
16 Q So you delivered the deeds to your mother?
17 A I did not deliver them to her, no.
18 Q Well, you found them?
19 A Yes.
20 Q What did you do with them?
21 A I held onto them.
22 Q You personally held onto them?
23 A Yeah; in our home.
24 Q So they were in a place of safe keeping in
25 your home?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
-
(518) 58"I 6832
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/23/2022
106
1 Zaharah Badrudin - Atty. Adang
2 A Yeah; that we all had access to.
3 Q That was some time in May of 2013?
4 A Sometime in '13 for sure, I think.
5 Q Following that, you created, in your words,
6 the deeds from your mother to your sister?
8 don't want it to be misconstrued. I meant my mom
9 deeded them to my sister. That's what we did.
10 Q Who prepared the deed conveying the
11 properties from your mother to your sister?
12 A I did, I think.
13 Q I'm going to show you Deposition Exhibit 6.
14 Can you identify that for me?
15 A It says, "Saratoga County, State of New
York."
16
17 Q Maybe if you look at the second page of that
18 document, you will be able to identify it.
19 A It says, "4 Pages, Recorded Deed, Saratoga
20 County Clerk.
21 Q The deed is from whom to whom?
22 A From Mohamed Badrudin to Yasmin Nurani.
23 Q Yasmin Nurani being Yasmin Badrudin?
24 A Yes.
25 Q Yasmin Nurani being your mother?
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. 60 RECEIVED NYSCEF: 06/23/2022
107
1 Zaharah Badrudin - Atty. Adang
2 A Yes.
3 Q And what's the date of that deed?
4 A 04/02/2007.
5 So what date is that? Is that April --
Q
6 A 2, 2017.
8 A Sorry; 2007.
9 Q Is that deed notarized?
10 A Yes.
11 Q By whom?
12 A I can't read the name. It's blurred.
13 Q Is there a stamp?
14 A The stamp is blurred.
15 Q Have you seen a copy or the original of that
16 deed before today?
17 A Yes.
18 Q Is it the original of that deed that you
19 discovered in the boxes of information at your home
20 at 22 Elizabeth Lane in early 2013?
21 A Yes.
22 Q And following your discovery of this deed,
23 you held onto it?
24 A Yes.
25 Q And was it in the same box that you found it
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. 60 RECEIVED NYSCEF: 06/23/2022
108
1 Zaharah Badrudin - Atty. Adang
2 or did you put it somewhere else?
3 A I couldn't say.
4 Q You can't say?
5 A Yeah.
6 Q Was this deed subsequently recorded in the
7 County Clerk's office?
8 A Yes.
9 Q By whom?
10 A I think we were all there.
11 Q Do you recall when it was recorded?
12 A No.
13 Q I'm going to ask you to look at the first
14 page. Does that show what date that that deed was
15 recorded in the Clerk's office?
16 A Yes; November 13, 2013.
17 Q The box that you found this in in your home
18 in 2000 -- I of I stand
May say May 2000, corrected,
19 in early 2013. Within the box that you found this
20 deed in, had that box, to your knowledge, ever been
21 in any other location other than 22 Elizabeth Lane
22 from the time of your father's death until the time
23 that you discovered them?
24 A It could have been.
25 Q Where could it have been?
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. 60 RECEIVED NYSCEF: 06/23/2022
109
1 Zaharah Badrudin - Atty. Adang
2 A It could have been in 175 Cronin Road.
3 Q Why 175 Cronin Road?
4 A Because my dad used that as an office so a
5 lot of his documents were there.
6 Q And he used that as an office, obviously,
7 before his death?
8 A Yes.
9 Q You rented 175 Cronin Road after the date of
10 his death?
11 A Yes.
12 Q When did you rent it?
13 A I can't say for sure when I rented it but it
14 was years after.
15 Q So between the time of his death and the
16 time you rented it, the box in which you located
17 this deed could have been on Cronin Road?
18 A Yes.
19 Q Could it have been anywhere else?
20 A Yeah; it could have been in our basement in
21 32 Purtell Avenue.
22 Q Did you go to Purtell Avenue between the
23 date of your father's death and the time that you
24 located these deeds?
25 A 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. 60 RECEIVED NYSCEF: 06/23/2022
110
1 Zaharah Badrudin - Atty. Adang
2 Q How often?
3 A Very often. I was doing a whole house
4 renovation.
5 Q But it's fair to say that the deeds were not
6 discovered by you until nearly five years after your
8 A Yeah.
9 Q I stand corrected.
10 A If I had seen it, I may not have even
11 recognized it though so I could have seen it.
12 Q You are not answering my question. I will
13 rephrase it.
14 A Okay.
15 Q Is it your testimony that you discovered
16 these deeds for the first time some time in May of
17 -- some time in 2013?
sorry early
18 A That's not my testimony, no.
19 Q What was your testimony? When did you
20 discover the deeds?
21 A My testimony is I found out what they were
22 in early 2013 and that's when I started asking
23 questions about them.
24 Q When did you discover them?
"discover"
25 A See, the word to me means if I
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. 60 RECEIVED NYSCEF: 06/23/2022
111
1 Zaharah Badrudin - Atty. Adang
2 found out what they were. I think to you it means
3 when I saw them for the first time. So I wanted to
4 make a distinction.
"discover"
5 Q I think the word means the same
6 to everybody.
7 When did you first locate this deed?
8 A I may have located it previously and not
9 known what it was.
10 Q When is the first time you discovered it and
11 knew what it was?
12 A Early 2013.
13 Q Nearly six years after the date of your
14 father's death, is that correct?
15 A Sure.
16 Q It's your testimony it was recorded by all
17 three of you at the Saratoga County Clerk's office?
18 A I think so. I don't remember exactly.
19 Q I show you Deposition Exhibit 7. Can you
20 identify that?
5217."
21 A It says, "Instructions RP
22 Q That form, does it deal with or relate to
23 the Bluebird Terrace Mobile Home Park?
A -- that's the
24 The address property location.
25 Property location 116 Bluebird Road, Moreau.
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. 60 RECEIVED NYSCEF: 06/23/2022
112
1 Zaharah Badrudin - Atty. Adang
2 Q In the lower left-hand corner, are there
3 spaces for a signature?
4 A Yes.
5 Q Is the seller identified?
6 A Yes.
8 A M. Badrudin.
9 Q M. Badrudin?
10 A Yes.
11 Q M. Badrudin had died in 2007, correct?
12 A It says Y. Nurani as POA for M. Badrudin.
13 Q Did Y. Nurani have a Power of Attorney from
14 M. Badrudin in 2013?
15 A I don't know.
16 Q But Y. Nurani signed that document as Power
17 of Attorney from Mohamed Badrudin in 2013, is that
18 correct?
19 A That's what it looks like here.
20 Q Do you know who prepared Deposition Exhibit
21 7?
22 A This form doesn't look familiar to me.
23 Q That's not what I asked you.
24 A So I couldn't say.
25 Q You can say. I asked you. Do you know who
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. 60 RECEIVED NYSCEF: 06/23/2022
113
1 Zaharah Badrudin - †tty. Adang
do"
2 prepared it, "yes, I or "no, I don't"?
3 A No, I don't.
4 Q Thank you.
5 I will show you Deposition Exhibit 8 and can
6 you identify that for me?
7 A Sure. It says, Deed, Four Pages, Recorded
Deed."
8
9 Q Deed from whom to whom?
10 A From Mohamed Badrudin to Yasmin Nurani.
11 Q What's the date of that deed?
12 A April 2, 2007.
13 Q What property is conveyed by that deed?
14 A 1262-1268 Route 9.
15 Q Is that the former Terry Hotel or Motel,
16 excuse me?
17 A Maybe.
18 Q If you know.
19 A I'm not sure.
20 Q Did you discover the original of that deed?
21 A I think so.
22 Q Contemporaneously when you discovered the
23 deed to the Bluebird Terrace Mobile Home Park?
24 A I think so.
25 Q What did you do with this deed?
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
58'7 - 6832
(518)
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/23/2022
114
1 Zaharah Badrudin - At .
ty Adang
2 A The same thing I did with the other deeds.
3 Q You asked a number of people?
4 A Yes.
5 Q And then ultimately you recorded it in the
6 Saratoga County Clerk's office?
7 A Yes.
8 Q Do you recall what date you recorded it?
9 A No.
10 Q Was it recorded contemporaneously with the
11 other deeds?
12 A What is "contemporaneously"?
13 Q At the same time.
14 A I don't know.
15 Q I show you Deposition Exhibit 9. For the
16 record, that is what is called a Real Property
17 Transfer Report. Does that have a space for
18 signature lines for the seller?
19 A Yes.
20 Q Who executed that?
21 A Y. Nurani as POA for M. Badrudin.
22 Q What's the date of that document?
23 A 11/12/13.
24 Q Thank you.
25 Getting back to the deeds that were created
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. 60 RECEIVED NYSCEF: 06/23/2022
115
Zaharah Badrudin - At .
1 ty Adang
2 from your mother to your sister Salimah, I believe
3 it was your testimony that you prepared the deed to
4 the Bluebird Terrace Mobile Home Park, is that
5 correct?
6 A I think I said I did.
7 Q Did you prepare the deeds from your mother
8 to Salimah for the other properties as well?
9 A I think so.
10 (Brief recess.)
11 (The record was read by the
12 reporter.)
13 EXAMINATION
14 BY MR. ADANG:
15 Q We are back on the record. You are still
16 under oath.
17 I will limit my questions just to the
18 Bluebird Terrace Mobile Home Park deed. After you
19 discovered it and were aware for the first time what
20 it was, you waited a number of months to have it
21 recorded in the Saratoga County Clerk's office, is
22 that a fair statement?
23 A Yes.
24 Q You spoke to a number of people in that
25 intervening period, correct, regarding what
Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/23/2022 101 1 Zaharah Badrudin - Atty. Adang 2 A Okay. I couldn't -- say 3 MR. ADANG: Off the record. 4 (An off-the-record discussion was had.) 5 A Now I can't say I for sure told them. You 6 can compel. 7 Q You testified so what is the name? 8 A I would like to change my testimony. I'm 9 not sure if I told them. I know I spoke to family 10 members. I can't say which ones specifically. 11 Q You are not sure you spoke to the lawyer 12 cousin that you are not sure that you spoke to? 13 A I'm not disclosing that. You can compel me 14 like you said you would. 15 Q I'm just going to ask the judge to compel 16 you to answer that question. 17 A Please. 18 Q Who else did you speak with? 19 A People I knew at the time. I couldn't say 20 their names. I couldn't remember if I spoke to them 21 or not. 22 Q So you spoke to people but you can't 23 remember the name or names of anybody that you spoke 24 to? 25 A The reason is because I spoke to so many 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. 60 RECEIVED NYSCEF: 06/23/2022 102 1 Zaharah Badrudin - Atty. Adang 2 people, I couldn't say I spoke definitively to this 3 person or I didn't speak definitively to this 4 person. I know I was trying to get information 5 everywhere I possibly could including talking to 6 attorneys in the phonebook for free consults as well 7 as Google search. 8 Q What attorneys did you consult with? 9 A I didn't keep a record of that. I don't 10 know them so I don't know their names. 11 Q You called an attorney or attorneys and 12 spoke to them? 13 A Yeah. 14 Q You can't remember any names? 15 A I called a lot of them. 16 Q Without being specific as to whom you spoke 17 to, what were you told? 18 A That I had to record it. 19 Q And what else were you told? 20 A That as soon as the deed was delivered to my 21 mom, that she was the owner of the property. 22 Q By whom? 23 A I don't remember their names. 24 Q You were told by someone that as soon as the 25 deed was delivered to your mother, she was the owner 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. 60 RECEIVED NYSCEF: 06/23/2022 103 1 Zaharah Badrudin - Atty. Adang 2 of the property? 3 A Yes. 4 Q At the time that you discovered the deeds, 5 was your father's estate proceeding pending in 6 Warren County Surrogate's Court? 7 A Yes. 8 Q Who was the representative of the estate at 9 that time? 10 A My mom. 11 Q Did you notify the Surrogate's Court 12 independently that you had located the deed or 13 deeds? 14 A No. 15 Q Do you know if your mother notified the 16 Surrogate's Court of the acquisition of these deeds? 17 A I don't think we spoke to the Court directly 18 so I don't think any of us. 19 Q Who did you speak to if not the Court 20 directly? 21 A We would have spoken to our attorney. 22 Q Did you speak to your attorney? 23 A I don't think so. 24 Q Did you have an attorney? 25 A I think so. 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. 60 RECEIVED NYSCEF: 06/23/2022 104 1 Zaharah Badrudin - Atty. Adang 2 Q Who was your attorney? 3 A Brad Krause. 4 Q He was your attorney or the estate attorney? 5 A I don't know this distinction. 6 Q So you told Mr. Krause? 7 A Yes. 8 Q Or Mr. Krause was told? -- 9 A No, no. I wasn't like I said, I'm not 10 sure if I told him. 11 Q Do you have any independent knowledge that 12 your mother told Mr. Krause? 13 A No. 14 Q Do you have any independent knowledge that 15 your sister told Mr. Krause? 16 A I wouldn't know. 17 Q You wouldn't know or you don't have any 18 independent knowledge? 19 A I wouldn't know if either of them told. 20 Q After you discovered the deeds with your 21 sister, did you deliver them to the possession of 22 your mother? 23 A No. 24 Q What did you do with them? 25 A After asking all these people, I think we 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. 60 RECEIVED NYSCEF: 06/23/2022 105 1 saharah Badrudin - Atty. Adang 2 created deeds going from my mother to my sister. 3 Q When did you do that? 4 A I don't know the date. 5 Q Why was that done? 6 A Because that's what my mom wanted to do. 7 Q What was the reason that your mom wanted to 8 do that? 9 A Because since my dad's death was such a 10 shock and my mom's health was never good, we didn't 11 want anything to happen to my mom and have to go 12 through more proceedings, I think. But I can't be 13 sure. That's what I thought it was. But I don't 14 think she told me that directly because I'm guessing 15 to what she is thinking basically. 16 Q So you delivered the deeds to your mother? 17 A I did not deliver them to her, no. 18 Q Well, you found them? 19 A Yes. 20 Q What did you do with them? 21 A I held onto them. 22 Q You personally held onto them? 23 A Yeah; in our home. 24 Q So they were in a place of safe keeping in 25 your home? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. - (518) 58"I 6832 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/23/2022 106 1 Zaharah Badrudin - Atty. Adang 2 A Yeah; that we all had access to. 3 Q That was some time in May of 2013? 4 A Sometime in '13 for sure, I think. 5 Q Following that, you created, in your words, 6 the deeds from your mother to your sister? 8 don't want it to be misconstrued. I meant my mom 9 deeded them to my sister. That's what we did. 10 Q Who prepared the deed conveying the 11 properties from your mother to your sister? 12 A I did, I think. 13 Q I'm going to show you Deposition Exhibit 6. 14 Can you identify that for me? 15 A It says, "Saratoga County, State of New York." 16 17 Q Maybe if you look at the second page of that 18 document, you will be able to identify it. 19 A It says, "4 Pages, Recorded Deed, Saratoga 20 County Clerk. 21 Q The deed is from whom to whom? 22 A From Mohamed Badrudin to Yasmin Nurani. 23 Q Yasmin Nurani being Yasmin Badrudin? 24 A Yes. 25 Q Yasmin Nurani being your mother? 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. 60 RECEIVED NYSCEF: 06/23/2022 107 1 Zaharah Badrudin - Atty. Adang 2 A Yes. 3 Q And what's the date of that deed? 4 A 04/02/2007. 5 So what date is that? Is that April -- Q 6 A 2, 2017. 8 A Sorry; 2007. 9 Q Is that deed notarized? 10 A Yes. 11 Q By whom? 12 A I can't read the name. It's blurred. 13 Q Is there a stamp? 14 A The stamp is blurred. 15 Q Have you seen a copy or the original of that 16 deed before today? 17 A Yes. 18 Q Is it the original of that deed that you 19 discovered in the boxes of information at your home 20 at 22 Elizabeth Lane in early 2013? 21 A Yes. 22 Q And following your discovery of this deed, 23 you held onto it? 24 A Yes. 25 Q And was it in the same box that you found it 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. 60 RECEIVED NYSCEF: 06/23/2022 108 1 Zaharah Badrudin - Atty. Adang 2 or did you put it somewhere else? 3 A I couldn't say. 4 Q You can't say? 5 A Yeah. 6 Q Was this deed subsequently recorded in the 7 County Clerk's office? 8 A Yes. 9 Q By whom? 10 A I think we were all there. 11 Q Do you recall when it was recorded? 12 A No. 13 Q I'm going to ask you to look at the first 14 page. Does that show what date that that deed was 15 recorded in the Clerk's office? 16 A Yes; November 13, 2013. 17 Q The box that you found this in in your home 18 in 2000 -- I of I stand May say May 2000, corrected, 19 in early 2013. Within the box that you found this 20 deed in, had that box, to your knowledge, ever been 21 in any other location other than 22 Elizabeth Lane 22 from the time of your father's death until the time 23 that you discovered them? 24 A It could have been. 25 Q Where could it have been? 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. 60 RECEIVED NYSCEF: 06/23/2022 109 1 Zaharah Badrudin - Atty. Adang 2 A It could have been in 175 Cronin Road. 3 Q Why 175 Cronin Road? 4 A Because my dad used that as an office so a 5 lot of his documents were there. 6 Q And he used that as an office, obviously, 7 before his death? 8 A Yes. 9 Q You rented 175 Cronin Road after the date of 10 his death? 11 A Yes. 12 Q When did you rent it? 13 A I can't say for sure when I rented it but it 14 was years after. 15 Q So between the time of his death and the 16 time you rented it, the box in which you located 17 this deed could have been on Cronin Road? 18 A Yes. 19 Q Could it have been anywhere else? 20 A Yeah; it could have been in our basement in 21 32 Purtell Avenue. 22 Q Did you go to Purtell Avenue between the 23 date of your father's death and the time that you 24 located these deeds? 25 A 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. 60 RECEIVED NYSCEF: 06/23/2022 110 1 Zaharah Badrudin - Atty. Adang 2 Q How often? 3 A Very often. I was doing a whole house 4 renovation. 5 Q But it's fair to say that the deeds were not 6 discovered by you until nearly five years after your 8 A Yeah. 9 Q I stand corrected. 10 A If I had seen it, I may not have even 11 recognized it though so I could have seen it. 12 Q You are not answering my question. I will 13 rephrase it. 14 A Okay. 15 Q Is it your testimony that you discovered 16 these deeds for the first time some time in May of 17 -- some time in 2013? sorry early 18 A That's not my testimony, no. 19 Q What was your testimony? When did you 20 discover the deeds? 21 A My testimony is I found out what they were 22 in early 2013 and that's when I started asking 23 questions about them. 24 Q When did you discover them? "discover" 25 A See, the word to me means if I 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. 60 RECEIVED NYSCEF: 06/23/2022 111 1 Zaharah Badrudin - Atty. Adang 2 found out what they were. I think to you it means 3 when I saw them for the first time. So I wanted to 4 make a distinction. "discover" 5 Q I think the word means the same 6 to everybody. 7 When did you first locate this deed? 8 A I may have located it previously and not 9 known what it was. 10 Q When is the first time you discovered it and 11 knew what it was? 12 A Early 2013. 13 Q Nearly six years after the date of your 14 father's death, is that correct? 15 A Sure. 16 Q It's your testimony it was recorded by all 17 three of you at the Saratoga County Clerk's office? 18 A I think so. I don't remember exactly. 19 Q I show you Deposition Exhibit 7. Can you 20 identify that? 5217." 21 A It says, "Instructions RP 22 Q That form, does it deal with or relate to 23 the Bluebird Terrace Mobile Home Park? A -- that's the 24 The address property location. 25 Property location 116 Bluebird Road, Moreau. 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. 60 RECEIVED NYSCEF: 06/23/2022 112 1 Zaharah Badrudin - Atty. Adang 2 Q In the lower left-hand corner, are there 3 spaces for a signature? 4 A Yes. 5 Q Is the seller identified? 6 A Yes. 8 A M. Badrudin. 9 Q M. Badrudin? 10 A Yes. 11 Q M. Badrudin had died in 2007, correct? 12 A It says Y. Nurani as POA for M. Badrudin. 13 Q Did Y. Nurani have a Power of Attorney from 14 M. Badrudin in 2013? 15 A I don't know. 16 Q But Y. Nurani signed that document as Power 17 of Attorney from Mohamed Badrudin in 2013, is that 18 correct? 19 A That's what it looks like here. 20 Q Do you know who prepared Deposition Exhibit 21 7? 22 A This form doesn't look familiar to me. 23 Q That's not what I asked you. 24 A So I couldn't say. 25 Q You can say. I asked you. Do you know who 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. 60 RECEIVED NYSCEF: 06/23/2022 113 1 Zaharah Badrudin - †tty. Adang do" 2 prepared it, "yes, I or "no, I don't"? 3 A No, I don't. 4 Q Thank you. 5 I will show you Deposition Exhibit 8 and can 6 you identify that for me? 7 A Sure. It says, Deed, Four Pages, Recorded Deed." 8 9 Q Deed from whom to whom? 10 A From Mohamed Badrudin to Yasmin Nurani. 11 Q What's the date of that deed? 12 A April 2, 2007. 13 Q What property is conveyed by that deed? 14 A 1262-1268 Route 9. 15 Q Is that the former Terry Hotel or Motel, 16 excuse me? 17 A Maybe. 18 Q If you know. 19 A I'm not sure. 20 Q Did you discover the original of that deed? 21 A I think so. 22 Q Contemporaneously when you discovered the 23 deed to the Bluebird Terrace Mobile Home Park? 24 A I think so. 25 Q What did you do with this deed? STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 58'7 - 6832 (518) FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 60 RECEIVED NYSCEF: 06/23/2022 114 1 Zaharah Badrudin - At . ty Adang 2 A The same thing I did with the other deeds. 3 Q You asked a number of people? 4 A Yes. 5 Q And then ultimately you recorded it in the 6 Saratoga County Clerk's office? 7 A Yes. 8 Q Do you recall what date you recorded it? 9 A No. 10 Q Was it recorded contemporaneously with the 11 other deeds? 12 A What is "contemporaneously"? 13 Q At the same time. 14 A I don't know. 15 Q I show you Deposition Exhibit 9. For the 16 record, that is what is called a Real Property 17 Transfer Report. Does that have a space for 18 signature lines for the seller? 19 A Yes. 20 Q Who executed that? 21 A Y. Nurani as POA for M. Badrudin. 22 Q What's the date of that document? 23 A 11/12/13. 24 Q Thank you. 25 Getting back to the deeds that were created 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. 60 RECEIVED NYSCEF: 06/23/2022 115 Zaharah Badrudin - At . 1 ty Adang 2 from your mother to your sister Salimah, I believe 3 it was your testimony that you prepared the deed to 4 the Bluebird Terrace Mobile Home Park, is that 5 correct? 6 A I think I said I did. 7 Q Did you prepare the deeds from your mother 8 to Salimah for the other properties as well? 9 A I think so. 10 (Brief recess.) 11 (The record was read by the 12 reporter.) 13 EXAMINATION 14 BY MR. ADANG: 15 Q We are back on the record. You are still 16 under oath. 17 I will limit my questions just to the 18 Bluebird Terrace Mobile Home Park deed. After you 19 discovered it and were aware for the first time what 20 it was, you waited a number of months to have it 21 recorded in the Saratoga County Clerk's office, is 22 that a fair statement? 23 A Yes. 24 Q You spoke to a number of people in that 25 intervening period, correct, regarding what