Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 06/23/2022
201
1 Zaharah Badrudin - At . Everhart
ty
2 were renting properties to ensure that the folks you
3 rented to were United States citizens, if any?
4 A I didn't take any steps.
5 Q Who primarily discussed rent with residents
6 of 32 Purtell Avenue?
. . --
--T-consider r ÿ[élf primary because my mom
8 I den-t consider-her capacity to be strong errougli.
9 Q So you were the one that set the rental
10 value for the 32 Purnell Avenue units?
11 A I think so.
12 Q You were the one that found residents for
13 the units?
14 A I could have had help but I think so.
15 Q In 2014, who was 32 Purtell Avenue rented
16 to?
17 A I don't know off the top of my head.
18 Q Can you think of anybody you rented 32
19 Purtell Avenue to?
20 A I wouldn't know their names.
21 Q Did you ever receive money orders from them?
22 A I think so.
23 Q Did they ever put their names on the money
24 orders?
25 A Yes. I mean, I assume so. I don't have
...
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. 65 RECEIVED NYSCEF: 06/23/2022
202
1 Zaharah Badrudin - Atty. Everhart
2 them in front of me.
3 Q Do you have any recollection who rented the
4 upstairs unit at 32 Purtell Avenue?
5 A No.
6 Q Ever?
. . .
--know at one point iTwas a man who
8 destroyed the place and didn'tpay rent-and he w s
9 there for a short amount of time.
10 Q You found a replacement for him?
11 A I think I think -- yes.
so.
12 Q Who did you find?
13 A I'm not sure of the names.
14 MS. S. BADRUDIN: Objection. All
15 the questions relating to 32 Purtell Avenue
16 are not relevant.
17 Q I want to move on to the tax returns you
18 said you prepared for your mother. Do you need them
19 in front of you in order to speak generically about
20 them?
21 A Not generically.
22 Q Have you taken any accounting courses?
23 A No.
24 Q Do you have a background in filling out tax
25 returns?
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. 65 RECEIVED NYSCEF: 06/23/2022
203
1 Zaharah Badrudin - Atty. Everhart
2 A I took a class once at the -- I don't
Well,
3 remember. They have a green sign on the door. I
4 took a class there once but I did not complete it.
5 Q What kind of a class was it?
6 A Tax preparation class.
7 Q Wãs tö ecome a tax preparer?
9 Q Was the entire instruction given in one
10 class or did you only attend the first of many
11 classes?
12 A I attended multiple of many classes.
13 Q Was the purpose of the class to become
14 certified?
15 A No; just to learn.
16 Q Was it a class you had to pay for?
17 A I'm not sure I paid for it. I'm not sure if
18 there was a rebate involved.
19 Q I'm asking, was this a free class to others?
20 A I don't know.
21 Q So when you prepared your mother's tax
22 returns, what was your method?
23 That was a horrible question. Let me ask it
24 a different way.
25 Did you hand write in the numbers? Did you
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. 65 RECEIVED NYSCEF: 06/23/2022
204
1 Zaharah Badrudin - Atty. Everhart
2 type them? Did you use a PDF? How did you fill the
3 actual form out for her?
4 A I think I had a rough draft and then I wrote
5 it in to the online version and printed it.
6 Q This was TurboTax? Did you use TurboTax or
7 some 75ther program?
8 I think used like the form directly from
9 the IRS website.
10 Q Am I understanding correctly that you used a
11 fill-inable PDF form?
12 A I think so; yes.
13 Q Did you ever make alterations to the form?
14 A While I was making them?
15 Q Did you prepare her entire tax return for
16 that year in one sitting or did you prepare it and
17 then come back and fix things or change things
18 later?
19 A I had a rough draft. When I was filling in
20 the PDF, I would just be typing so I wouldn't make
21 changes later.
22 Q Did you ever save the form to a computer you
23 were working on?
24 A I don't think you could at the time. I
25 think you had to print them.
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. 65 RECEIVED NYSCEF: 06/23/2022
205
1 Zaharah Badrudin - Atty. Everhart
2 Q Do you remember saving the form to the
3 computer you were working on?
4 A I don't remember; no.
5 Q If you had saved the forms to your computer,
6 would they be on the computer?
The computer I had sold on Craigslist.
8 Q When did that happen?
9 A I like to sell my computers every year. I
10 buy them on Black Friday, then I sell them for the
11 same price the next year.
12 Q Is it your testimony each and every one of
13 these tax returns that you prepared for your mother
14 were done on separate computers?
15 A I think so; according to my pattern of
16 buying computers.
17 Q Moving back to the deeds of the properties
-- issue,"
18 at issue when I say "the properties at
19 I'm talking about the properties listed in Exhibit 5
20 that are before you. Do you understand that?
21 A Yes.
22 Q I want to get back to the deeds that purport
23 to convey certain of those properties from your
24 father to your mother. Okay?
25 A Okay.
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. 65 RECEIVED NYSCEF: 06/23/2022
206
1 Zaharah Badrudin - At . Everhart
ty
2 Q You indicated that you found out about these
3 deeds some time around early 2013, is that fair?
4 A That's when I realized what they were.
5 Q When did you realize they existed?
6 A I couldn't say because I didn't know what
.
They were.
8 Q When did you realize that these deeds
9 existed?
10 A I would say when I figured out what they
11 were, that's when I knew they were deeds.
12 Q Do you remember seeing them at a time before
13 you realized they were deeds?
14 A If I had, I wouldn't have remembered it
15 because it was not important to me.
16 Q So the answer is no?
17 A It means I don't remember.
18 MS. EVERHART: Read back the
19 question.
20 (The pending question was read by
21 the reporter.)
22 A I don't remember.
23 Q So the answer is "no"?
24 A No; I do not remember.
25 Q After you and your sister discovered the
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. 65 RECEIVED NYSCEF: 06/23/2022
207
1 Zaharah Badrudin - At . Everhart
ty
2 deeds, understanding what they were some time in
3 early 2013, how did you tell your mother that you
4 had found them?
5 A I don't remember.
6 Q When did you tell her that you had found
8 A I don't know.
9 Q Do you remember what her reaction was to you
10 having discovered these deeds?
11 A Not really.
12 Q Do you remember if she was happy?
13 A Her moods are really hard to tell.
14 Q Were you happy that you had found them?
15 A No.
16 Q Were you sad that you had found them?
17 A No.
18 Q Did you have any emotional response to
19 having discovered them whatsoever?
A because didn't realize -- knew
20 No, I I what
21 they were but they weren't recorded so I wasn't sure
22 what to do with them.
23 Q But you realized what they were at some time
24 in early 2013. Did that realization, was that a
25 good realization or a balanced realization? Did you
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. 65 RECEIVED NYSCEF: 06/23/2022
208
1 Zaharah Badrudin - At . Everhart
ty
2 not care?
3 A It made sense, that realization. That's how
4 I felt, it made sense.
5 Q Why?
6 A Just because, you know, he wrote the will to
my mom aild my mom was saying they existed earlier
--
8 and he made the life insurance at the same time
9 couple of months before that and just with
10 conversations with him, it made sense that he would
11 want to protect us in that way.
12 Q What else did he own at the time of his
13 death, if you know, other than the properties, other
14 than the life insurance that you just mentioned?
15 Did he have any other assets?
16 A Not that I can think of.
17 Q Did he own any cars?
18 A Yes; he owned a Mazda.
19 Q Prior to his death, did he sign that title
20 over to anybody?
21 A No.
22 Q Did he own any other vehicles?
23 A I think he may have owned our Corolla but
24 I'm not sure.
25 Q Do you ever remember seeing the Corolla
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. 65 RECEIVED NYSCEF: 06/23/2022
209
1 Zaharah Badrudin - Atty. Everhart
2 being signed over from your father to anybody else?
3 Did your father sign the Corolla over to anybody?
4 A I don't remember. It was a '99 Corolla. It
5 was an old one so I don't remember it.
6 Q In the months prior to your father's death,
7 -----drd-h-tr-sign any tif his bank accounts over to anybody
8 else, to your knowledge?
9 A To my knowledge, no.
10 Q So out of all of the assets he had in his
11 name, it was only the real property that he signed
12 over to your mother?
13 A Well, no.
14 Q What else was signed over to your mother?
15 A I think with the will, you would say he is
16 trying to give everything to my mom. With the life
17 insurance. He is trying to protect us. So I think
18 the bank accounts had no money in them. It would
19 make sense he would not sign them over. And we all
20 used them anyway all together so I don't think...
21 Q I will try the guestion again.
22 Out of all of the assets that were in your
23 father's name at the time of death, the real
24 property were the only assets he turned over to your
25 mother just prior to his death, is that true?
S TEPHANIE PI COZ Z I , 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. 65 RECEIVED NYSCEF: 06/23/2022
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1 Eaharah Badrudin - Atty. Everhart
2 A Can you list all the assets?
3 Q No, I can't.
4 A Then I can't answer that question.
'
5 Q Let s try again.
6 Did your father own any vehicles at the time
8 A Yes.
9 Q So we have got vehicles.
10 Did your father have any accounts at the
11 time of his death?
12 A Yes.
13 Q Okay. We have accounts.
14 Did he own any parcels of real property
15 prior to his death, in the months prior to his
16 death?
17 A Yes.
18 Q So out of all of those assets we have just
19 talked about, did he sign anything other than the
20 properties over to your mother?
21 A He only signed the one that had the value.
22 The cars had no value.
"Yes" "no,"
23 Q or to your knowledge, did he
24 sign over any of the other assets to your mother
25 prior to his death?
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. 65 RECEIVED NYSCEF: 06/23/2022
211
1 Zaharah Badrudin - Atty. Everhart
2 A He didn't sign over the car or the bank
3 accounts, no.
4 Q At what point did you learn from your mother
5 that the deeds to these properties existed?
6 A I couldn't say.
8 A Because it was a long time ago.
9 Q How long ago?
10 A I don't know.
11 Q Prior to your father's death?
12 A I couldn't be sure.
13 Q Do you have any way of narrowing it down, to
14 your recollection?
15 A Not that I can think of right now.
16 Q When you filled out Exhibit 5 before you,
17 had you been made aware of the possible existence of
18 deeds you hadn't yet discovered?
19 A I'm not sure.
20 Q So at some point you found these deeds and
21 at some point you knew what they were. At some
22 point you told your mother based upon your
23 testimony. At some point thereafter you drafted
24 deeds from your mother to your sister. All of that
25 correct?
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. 65 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Everhart
2 A Yes.
3 Q What was your process in drafting deeds from
4 your mother to your sister?
5 A Can you define "process"?
6 Q What were the steps you took?
8 Q What form?
9 A The quitclaim deed form.
10 Q Who gave you the quitclaim deed form?
11 A I don't know.
12 Q Did someone give you the quitclaim deed
13 form?
14 A I don't know. I don't know where I got that
15 form.
16 Q Did you ever consult with an attorney in
17 order to the quitclaim deed forms?
18 A I don't know. I spoke to a bunch of those
19 free attorneys.
20 Q Did you ever pay an attorney for the
21 assistance of the conveyance of the property from
22 your mother to your sister?
23 A No.
24 Q I'm showing you what's been marked as
25 Exhibit 6. Do you recognize that document?
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. 65 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Everhart
2 A It looks familiar.
3 Q Is that one of the deeds we have been
4 talking about?
5 A Yes.
6 Q Is that one of the deeds you filled out?
7 A No.
8 Q You didn't fill out that deed?
9 A No; it's from my father to my mother.
10 Q Can you pass that back? I apologize.
11 Were you involved in any way in the drafting
12 of the deeds from your father to your mother?
13 A I don't know. I don't think so.
14 Q To your knowledge, was your mother involved
15 in that process?
16 A I wouldn't know.
17 Q To your knowledge, was your sister involved
18 in that process?
19 A I don't know.
20 Q To your knowledge, did your father employ
21 any attorneys to assist him in that process?
22 A I don't know.
23 Q I'm handing you back what's been marked as
24 Exhibit 6 and turn to the third page down at the
25 very bottom. Do you see it says R and R?
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. 65 RECEIVED NYSCEF: 06/23/2022
214
1 Zaharah Badrudin - Atty. Everhart
2 A Yes.
3 Q Do you see a name following that?
4 A Joseph M. Cairo.
5 Q What other information is contained other
6 than his name?
7 A P.O. Box 437, Waterford, New York 12188.
8 Q Are there any initials following his name?
9 A Esq.
10 Q Have you ever seen those initials following
11 any names before?
12 A Yes.
13 Q What's your understanding of those initials?
14 A It means esquire.
15 Q And what does that mean?
16 A Attorney.
17 Q Have you ever heard of that attorney before?
18 A The name sounds familiar.
19 Q Did you ever write checks to that attorney?
20 A I personally didn't. I don't think so.
21 Q Have you ever met that attorney?
22 A I couldn't say for sure.
23 Q Do you recall ever meeting that attorney?
24 A I don't remember.
25 Q So I know that you testified that you don't
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. 65 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - At . Everhart
ty
2 remember the location of the deeds when you
deeds,"
3 discovered them. And by "the I'm talking
4 about the deeds from your father to your mother. If
5 I'm understanding correctly, you don't remember what
6 container they were in, you don't remember what
7 other documents they were with and you don't
8 remember what structure they were found in at the
9 time you discovered them. Is all of that a fair
10 statement?
11 A
Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 65 RECEIVED NYSCEF: 06/23/2022 201 1 Zaharah Badrudin - At . Everhart ty 2 were renting properties to ensure that the folks you 3 rented to were United States citizens, if any? 4 A I didn't take any steps. 5 Q Who primarily discussed rent with residents 6 of 32 Purtell Avenue? . . -- --T-consider r ÿ[élf primary because my mom 8 I den-t consider-her capacity to be strong errougli. 9 Q So you were the one that set the rental 10 value for the 32 Purnell Avenue units? 11 A I think so. 12 Q You were the one that found residents for 13 the units? 14 A I could have had help but I think so. 15 Q In 2014, who was 32 Purtell Avenue rented 16 to? 17 A I don't know off the top of my head. 18 Q Can you think of anybody you rented 32 19 Purtell Avenue to? 20 A I wouldn't know their names. 21 Q Did you ever receive money orders from them? 22 A I think so. 23 Q Did they ever put their names on the money 24 orders? 25 A Yes. I mean, I assume so. I don't have ... 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. 65 RECEIVED NYSCEF: 06/23/2022 202 1 Zaharah Badrudin - Atty. Everhart 2 them in front of me. 3 Q Do you have any recollection who rented the 4 upstairs unit at 32 Purtell Avenue? 5 A No. 6 Q Ever? . . . --know at one point iTwas a man who 8 destroyed the place and didn'tpay rent-and he w s 9 there for a short amount of time. 10 Q You found a replacement for him? 11 A I think I think -- yes. so. 12 Q Who did you find? 13 A I'm not sure of the names. 14 MS. S. BADRUDIN: Objection. All 15 the questions relating to 32 Purtell Avenue 16 are not relevant. 17 Q I want to move on to the tax returns you 18 said you prepared for your mother. Do you need them 19 in front of you in order to speak generically about 20 them? 21 A Not generically. 22 Q Have you taken any accounting courses? 23 A No. 24 Q Do you have a background in filling out tax 25 returns? 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. 65 RECEIVED NYSCEF: 06/23/2022 203 1 Zaharah Badrudin - Atty. Everhart 2 A I took a class once at the -- I don't Well, 3 remember. They have a green sign on the door. I 4 took a class there once but I did not complete it. 5 Q What kind of a class was it? 6 A Tax preparation class. 7 Q Wãs tö ecome a tax preparer? 9 Q Was the entire instruction given in one 10 class or did you only attend the first of many 11 classes? 12 A I attended multiple of many classes. 13 Q Was the purpose of the class to become 14 certified? 15 A No; just to learn. 16 Q Was it a class you had to pay for? 17 A I'm not sure I paid for it. I'm not sure if 18 there was a rebate involved. 19 Q I'm asking, was this a free class to others? 20 A I don't know. 21 Q So when you prepared your mother's tax 22 returns, what was your method? 23 That was a horrible question. Let me ask it 24 a different way. 25 Did you hand write in the numbers? Did you 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. 65 RECEIVED NYSCEF: 06/23/2022 204 1 Zaharah Badrudin - Atty. Everhart 2 type them? Did you use a PDF? How did you fill the 3 actual form out for her? 4 A I think I had a rough draft and then I wrote 5 it in to the online version and printed it. 6 Q This was TurboTax? Did you use TurboTax or 7 some 75ther program? 8 I think used like the form directly from 9 the IRS website. 10 Q Am I understanding correctly that you used a 11 fill-inable PDF form? 12 A I think so; yes. 13 Q Did you ever make alterations to the form? 14 A While I was making them? 15 Q Did you prepare her entire tax return for 16 that year in one sitting or did you prepare it and 17 then come back and fix things or change things 18 later? 19 A I had a rough draft. When I was filling in 20 the PDF, I would just be typing so I wouldn't make 21 changes later. 22 Q Did you ever save the form to a computer you 23 were working on? 24 A I don't think you could at the time. I 25 think you had to print them. 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. 65 RECEIVED NYSCEF: 06/23/2022 205 1 Zaharah Badrudin - Atty. Everhart 2 Q Do you remember saving the form to the 3 computer you were working on? 4 A I don't remember; no. 5 Q If you had saved the forms to your computer, 6 would they be on the computer? The computer I had sold on Craigslist. 8 Q When did that happen? 9 A I like to sell my computers every year. I 10 buy them on Black Friday, then I sell them for the 11 same price the next year. 12 Q Is it your testimony each and every one of 13 these tax returns that you prepared for your mother 14 were done on separate computers? 15 A I think so; according to my pattern of 16 buying computers. 17 Q Moving back to the deeds of the properties -- issue," 18 at issue when I say "the properties at 19 I'm talking about the properties listed in Exhibit 5 20 that are before you. Do you understand that? 21 A Yes. 22 Q I want to get back to the deeds that purport 23 to convey certain of those properties from your 24 father to your mother. Okay? 25 A Okay. 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. 65 RECEIVED NYSCEF: 06/23/2022 206 1 Zaharah Badrudin - At . Everhart ty 2 Q You indicated that you found out about these 3 deeds some time around early 2013, is that fair? 4 A That's when I realized what they were. 5 Q When did you realize they existed? 6 A I couldn't say because I didn't know what . They were. 8 Q When did you realize that these deeds 9 existed? 10 A I would say when I figured out what they 11 were, that's when I knew they were deeds. 12 Q Do you remember seeing them at a time before 13 you realized they were deeds? 14 A If I had, I wouldn't have remembered it 15 because it was not important to me. 16 Q So the answer is no? 17 A It means I don't remember. 18 MS. EVERHART: Read back the 19 question. 20 (The pending question was read by 21 the reporter.) 22 A I don't remember. 23 Q So the answer is "no"? 24 A No; I do not remember. 25 Q After you and your sister discovered the 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. 65 RECEIVED NYSCEF: 06/23/2022 207 1 Zaharah Badrudin - At . Everhart ty 2 deeds, understanding what they were some time in 3 early 2013, how did you tell your mother that you 4 had found them? 5 A I don't remember. 6 Q When did you tell her that you had found 8 A I don't know. 9 Q Do you remember what her reaction was to you 10 having discovered these deeds? 11 A Not really. 12 Q Do you remember if she was happy? 13 A Her moods are really hard to tell. 14 Q Were you happy that you had found them? 15 A No. 16 Q Were you sad that you had found them? 17 A No. 18 Q Did you have any emotional response to 19 having discovered them whatsoever? A because didn't realize -- knew 20 No, I I what 21 they were but they weren't recorded so I wasn't sure 22 what to do with them. 23 Q But you realized what they were at some time 24 in early 2013. Did that realization, was that a 25 good realization or a balanced realization? Did you 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. 65 RECEIVED NYSCEF: 06/23/2022 208 1 Zaharah Badrudin - At . Everhart ty 2 not care? 3 A It made sense, that realization. That's how 4 I felt, it made sense. 5 Q Why? 6 A Just because, you know, he wrote the will to my mom aild my mom was saying they existed earlier -- 8 and he made the life insurance at the same time 9 couple of months before that and just with 10 conversations with him, it made sense that he would 11 want to protect us in that way. 12 Q What else did he own at the time of his 13 death, if you know, other than the properties, other 14 than the life insurance that you just mentioned? 15 Did he have any other assets? 16 A Not that I can think of. 17 Q Did he own any cars? 18 A Yes; he owned a Mazda. 19 Q Prior to his death, did he sign that title 20 over to anybody? 21 A No. 22 Q Did he own any other vehicles? 23 A I think he may have owned our Corolla but 24 I'm not sure. 25 Q Do you ever remember seeing the Corolla 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. 65 RECEIVED NYSCEF: 06/23/2022 209 1 Zaharah Badrudin - Atty. Everhart 2 being signed over from your father to anybody else? 3 Did your father sign the Corolla over to anybody? 4 A I don't remember. It was a '99 Corolla. It 5 was an old one so I don't remember it. 6 Q In the months prior to your father's death, 7 -----drd-h-tr-sign any tif his bank accounts over to anybody 8 else, to your knowledge? 9 A To my knowledge, no. 10 Q So out of all of the assets he had in his 11 name, it was only the real property that he signed 12 over to your mother? 13 A Well, no. 14 Q What else was signed over to your mother? 15 A I think with the will, you would say he is 16 trying to give everything to my mom. With the life 17 insurance. He is trying to protect us. So I think 18 the bank accounts had no money in them. It would 19 make sense he would not sign them over. And we all 20 used them anyway all together so I don't think... 21 Q I will try the guestion again. 22 Out of all of the assets that were in your 23 father's name at the time of death, the real 24 property were the only assets he turned over to your 25 mother just prior to his death, is that true? S TEPHANIE PI COZ Z I , 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. 65 RECEIVED NYSCEF: 06/23/2022 210 1 Eaharah Badrudin - Atty. Everhart 2 A Can you list all the assets? 3 Q No, I can't. 4 A Then I can't answer that question. ' 5 Q Let s try again. 6 Did your father own any vehicles at the time 8 A Yes. 9 Q So we have got vehicles. 10 Did your father have any accounts at the 11 time of his death? 12 A Yes. 13 Q Okay. We have accounts. 14 Did he own any parcels of real property 15 prior to his death, in the months prior to his 16 death? 17 A Yes. 18 Q So out of all of those assets we have just 19 talked about, did he sign anything other than the 20 properties over to your mother? 21 A He only signed the one that had the value. 22 The cars had no value. "Yes" "no," 23 Q or to your knowledge, did he 24 sign over any of the other assets to your mother 25 prior to his death? 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. 65 RECEIVED NYSCEF: 06/23/2022 211 1 Zaharah Badrudin - Atty. Everhart 2 A He didn't sign over the car or the bank 3 accounts, no. 4 Q At what point did you learn from your mother 5 that the deeds to these properties existed? 6 A I couldn't say. 8 A Because it was a long time ago. 9 Q How long ago? 10 A I don't know. 11 Q Prior to your father's death? 12 A I couldn't be sure. 13 Q Do you have any way of narrowing it down, to 14 your recollection? 15 A Not that I can think of right now. 16 Q When you filled out Exhibit 5 before you, 17 had you been made aware of the possible existence of 18 deeds you hadn't yet discovered? 19 A I'm not sure. 20 Q So at some point you found these deeds and 21 at some point you knew what they were. At some 22 point you told your mother based upon your 23 testimony. At some point thereafter you drafted 24 deeds from your mother to your sister. All of that 25 correct? 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. 65 RECEIVED NYSCEF: 06/23/2022 212 1 Zaharah Badrudin - Atty. Everhart 2 A Yes. 3 Q What was your process in drafting deeds from 4 your mother to your sister? 5 A Can you define "process"? 6 Q What were the steps you took? 8 Q What form? 9 A The quitclaim deed form. 10 Q Who gave you the quitclaim deed form? 11 A I don't know. 12 Q Did someone give you the quitclaim deed 13 form? 14 A I don't know. I don't know where I got that 15 form. 16 Q Did you ever consult with an attorney in 17 order to the quitclaim deed forms? 18 A I don't know. I spoke to a bunch of those 19 free attorneys. 20 Q Did you ever pay an attorney for the 21 assistance of the conveyance of the property from 22 your mother to your sister? 23 A No. 24 Q I'm showing you what's been marked as 25 Exhibit 6. Do you recognize that document? 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. 65 RECEIVED NYSCEF: 06/23/2022 213 1 Zaharah Badrudin - Atty. Everhart 2 A It looks familiar. 3 Q Is that one of the deeds we have been 4 talking about? 5 A Yes. 6 Q Is that one of the deeds you filled out? 7 A No. 8 Q You didn't fill out that deed? 9 A No; it's from my father to my mother. 10 Q Can you pass that back? I apologize. 11 Were you involved in any way in the drafting 12 of the deeds from your father to your mother? 13 A I don't know. I don't think so. 14 Q To your knowledge, was your mother involved 15 in that process? 16 A I wouldn't know. 17 Q To your knowledge, was your sister involved 18 in that process? 19 A I don't know. 20 Q To your knowledge, did your father employ 21 any attorneys to assist him in that process? 22 A I don't know. 23 Q I'm handing you back what's been marked as 24 Exhibit 6 and turn to the third page down at the 25 very bottom. Do you see it says R and R? 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. 65 RECEIVED NYSCEF: 06/23/2022 214 1 Zaharah Badrudin - Atty. Everhart 2 A Yes. 3 Q Do you see a name following that? 4 A Joseph M. Cairo. 5 Q What other information is contained other 6 than his name? 7 A P.O. Box 437, Waterford, New York 12188. 8 Q Are there any initials following his name? 9 A Esq. 10 Q Have you ever seen those initials following 11 any names before? 12 A Yes. 13 Q What's your understanding of those initials? 14 A It means esquire. 15 Q And what does that mean? 16 A Attorney. 17 Q Have you ever heard of that attorney before? 18 A The name sounds familiar. 19 Q Did you ever write checks to that attorney? 20 A I personally didn't. I don't think so. 21 Q Have you ever met that attorney? 22 A I couldn't say for sure. 23 Q Do you recall ever meeting that attorney? 24 A I don't remember. 25 Q So I know that you testified that you don't 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. 65 RECEIVED NYSCEF: 06/23/2022 215 1 Zaharah Badrudin - At . Everhart ty 2 remember the location of the deeds when you deeds," 3 discovered them. And by "the I'm talking 4 about the deeds from your father to your mother. If 5 I'm understanding correctly, you don't remember what 6 container they were in, you don't remember what 7 other documents they were with and you don't 8 remember what structure they were found in at the 9 time you discovered them. Is all of that a fair 10 statement? 11 A