Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 else?
3 A He would tell me. The Town would tell me.
4 New York State inspector told me. In fact, he
5 showed me a log of all the times he went. It's a
6 small town. People tell each other.
7 Q Did you give him permission?
8 A I understood it was part of his due
9 diligence so I didn't give him permission. I didn't
10 tell him he couldn't but -- didn't tell him he
11 couldn't.
12 Q More than a year of due diligence?
13 A I know he went to the Town. I know he
14 started going to the Town before we ever signed this
15 contract that was signed in March 14, 2014. I know
16 he was already talking to the Town at that time.
17 MR. ADANG: I object to the form of
18 the question.
19 Q So how long did you think due diligence
20 would last?
21 A I wasn't sure how long it would last.
22 Q How long did his last?
23 A His due diligence started before he entered
into -- before the date of March 2014 when we
24 14,
25 signed this agreement for purchase and sale of real
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 -
(518) 6832
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 estate. It had already started because as part of
3 this contract, we included letters from the Town and
--
4 different issues that were already part of
5 because we started the due diligence when we met
6 which was at the end of 2013 beginning of 2014.
7 Q Approximately how many months is that?
8 A About -- I couldn't for
approximately say
9 sure. More than -- it was -- I couldn't for
say
sure but would it was at least -- more than
10 I say
11 five months.
12 Q When he went to the park, did he do any
13 work?
14 A Yes; he dug up all the septic systems. So I
15 showed him where all the septic systems were. So he
16 brought two people with him. They dug it up and
17 looked at it. But, no, he did a lot of
18 drive-throughs, spoke to a lot of people, commented
19 on snow removal, grass, what he would do to improve
20 it.
21 Q Do you remember if he dug up all the septic
22 systems before or after the agreement was signed?
23 A I think it was after.
24 Q Did he do any work before the agreement?
25 A He went to the Town before the agreement and
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 the Health Department and the Town and Health
3 Department.
4 MR. ADANG: I'm going to object to
5 the form of the question.
6 Q Was any work done by him? Do you know of
7 anything done by him before the agreement was
8 signed?
9 A Yes. I know he went to the town and spoke
10 to the inspectors.
11 MR. ADANG: Object to the form of
12 the question. You can answer.
13 Q I will rephrase.
14 MR. ADANG: We are off the record.
15 (An off-the-record discussion was had.)
16 Q What specifically did he do before this
17 agreement was signed?
18 A He went to the Town and spoke to the
19 inspectors. We spoke at length, me and him. And we
met also multiple times. He collected -- he
20 asked
21 for information from me I think regarding who paid,
22 how much, were trailers owned by us or owned by
23 residents. He went to New York State Department of
24 Health to see if we had outstanding violations, if
25 our permit was okay. He went to the Town of Moreau
STEPHANIE PICOZZI, CRR, RPR
Martin Deposition Services, Inc.
587 -
(518) 6832
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538
NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 to do the same. And I believe he also in the same
went and made sure that our -- he
3 building looked at
4 our school and property tax and water bills.
5 Q Did he go anywhere else?
6 A Yes; he went to the park. He drove around
7 the park. He spoke to people.
8 Q Any other institutions?
9 MR. ADANG: Are you asking a
10 question?
11 MS. S. BADRUDIN: Yes.
12 MR. ADANG: Ask it so we can hear
13 it. Let her finish the answer to your
14 first question.
15 Are you finished?
16 THE WITNESS: Yes.
17 MR. ADANG: Now you can ask another
18 question.
19 Q Any other institutions?
20 A Yes. He went to the company that pumps our
21 septic system and inquired about the pumping
22 records. I believe he followed up on information in
23 our Department of Health file regarding our engineer
24 but I'm not sure of that. I do know he went to the
place where -- our to inquire
25 pumping company
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 because he told me and they told me as well.
3 Q How did you feel about that?
4 A Well, I felt like at least he was doing his
5 due diligence. I felt like I wanted to do whatever
6 I could to give him as much information, whatever he
7 asked for, so that he has the full picture.
8 Q What did he ask for?
9 A He asked for the rent, who was paying how
10 much, which ones were vacant, which ones were owned
11 by us, which were owned by people in the park.
12 Information regarding the STAR rebate program.
13 Information the work -- had some
regarding we
14 outstanding issues with the Town regarding condemned
15 properties and our plan how we will fix it. He
16 asked for the taxes.
17 Q What did you tell him about the taxes?
18 A I told him that I was missing one of the
19 years and he said that it would be fine. And I told
20 him I didn't have 2013 done yet. I hadn't filed it
21 because I file in October. And he said, "just do
22 the section that pertains to us and give that to me
income."
23 because I need it to verify
24 Q Were you certain that he was going to be
25 buying the 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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 A No. He was asking so many questions. They
3 kept delaying the closing date. They delayed it
4 multiple times because I think they were looking for
5 more information or he didn't get the mortgage.
6 There was an issue he had. And I wasn't sure that
7 it was going to go through and that made me angry
8 because he told everybody and people stopped paying
9 me.
10 Q Do you know approximately how many times
11 they delayed it?
12 A At least twice. And they kept asking for
13 more information.
14 Q Do you know the time frame, how long?
A think --
15 I
16 Q Do you know the time frame?
A think -- couldn't be
17 I the first I sure but
18 I think it was moved twice in May and June but I'm
19 not sure.
20 Q Did you know if you could sell the property?
21 A I thought I could sell the property because
22 of the deeds.
23 Q So who did you think was the owner of the
24 park?
25 A Salimah Badrudin.
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 Q So you thought she can sell the property?
3 A Yes.
4 MS. EVERHART: Object to form of the
5 last question.
6 To clarify for the record, Salimah
7 Badrudin is present and is the person
8 asking questions here as a pro se witness,
9 not as an attorney.
10 Go ahead.
11 Q So did you know if Salimah wanted to sell
12 the property?
13 MR. ADANG: It's the same objection.
14 Q Do you know Ms. Koolsam?
15 A Yes.
16 Q What's her story?
17 MR. ADANG: I will object to the
18 form of the question.
19 Q What do you know about her?
A know that first heard she came on -- she
20 I I
21 put in a claim in my dad's estate in 2009 I think,
about -- she was dad's
22 not sure, saying that my
23 divorced ex-wife. She had given a child support
--
24 order. She was saying she ran could not find my
25 father for years because she could not find him
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - S. Badrudin
2 based on his last name. She didn't know the last
3 name. It wasn't her married name. And so she said
4 all that under oath.
5 In 2013 she said, "hold on a second. Hold
6 on a second. I was looking for him. He is my
husband. never --
7 I was able to get married never
8 able to get married because I could not find him and
him."
9 I was married to And so that was her story.
10 She was saying, "I am the wife. I am Yasmin
Badrudin." --
11 The name she said she didn't know
12 Badrudin is the name that she claims to be and then
13 she changed her name to Yasmin K. Badrudin after I
14 think it was 40 years since her marriage, in 40
15 years since she saw him last and said she wants to
16 put in a claim for -- I think to she was married
say
17 to my dad. But she was married to my dad. And so
18 this, I think, happened in 2013. And since then,
19 she has been representing herself as Yasmin
20 Badrudin.
21 Q Did she do any work in the park?
A -- don't think ever met
22 No. We have not I I
23 her until I saw her in court in 2009.
24 Q Did you talk to anyone else about selling
25 the park?
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Adang
2 A Did I talk to anyone about selling it? Who
3 are you referring to as "anyone"?
4 Q Any attorneys?
5 A About whether I could sell or about selling
6 the park?
7 Q Either.
8 A Okay. About whether I could sell, yes. I
9 spoke to multiple attorneys in my phone
10 conversations and I understood it to mean that if
11 the deed was because my dad had given it to my mom,
12 it was valid and we could record it and sell it.
13 And did I talk to any attorneys regarding the sale?
14 I don't remember specifically talking to any
15 attorneys.
16 Q Just to clarify, what information did you
17 give Mr. Cannone?
A gave him --
18 I
19 MR. ADANG: I will object to the
20 form of that question. I think that's been
21 asked and answered on multiple occasions.
22 MS. S. BADRUDIN: That's all I have.
23 EXAMINATION
24 BY MR. ADANG:
25 Q Ms. Badrudin, you just testified that 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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Adang
2 spoke to attorneys about whether or not you could
3 sell the mobile home park?
4 A It's about what I could do with the deed.
I think --
5 Q
6 A That's what I meant, what I could do with
7 the deed.
8 Q Salimah Badrudin asked you if you had spoken
9 to attorneys about whether you could sell the mobile
10 home park. I believe your testimony was that you
11 did speak to attorneys about whether or not you
12 could sell it.
13 A I was referencing what to do with the deed,
14 the same scenario I previously talked about, the
15 same situation.
16 Q I think those are two different situations.
17 A I understood the question to mean that. I'm
18 sorry.
19 Q Understood whose question?
20 A My sister's question to mean what process
21 did you take with these deeds. That's the question
22 I was answering.
23 Q She didn't ask what process you went
24 through. She asked you if you spoke to attorneys
25 about whether or not you could sell the property.
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - At .
ty Adang
2 My question is, why would you speak with
3 attorneys about whether or not you could sell the
4 property when you testified earlier it was your
5 belief that your sister owned the property?
A -- when that
6 Right, so I was saying earlier
7 in response to my sister's question, I was referring
8 . to what to do with the deeds and that's when I
9 understood that they were her property which means
10 she could sell. That's what I responded as I wasn't
11 -- so that's where got could sell
I from. They are
12 her property. That's how I went back to the deeds
13 in my mind.
14 Sorry if I didn't answer the question the
15 way it was intended. I answered it the way I
16 understood her question to mean.
17 Q You testified earlier that Mr. Cannone asked
18 you to provide him with Schedule E to the 2000
19 return prior to the closing, is that correct?
20 A Yes.
21 Q And I believe your testimony was that you
22 advised him that the return had not been filed at
that point --
23
24 A Yes.
-- that correct?
25 Q is
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Adang
2 It was also your testimony that you filed
3 the return in October of 2014 after the closing?
4 A I think I said that is when I normally file.
5 I didn't have it ready at the time. So I didn't
6 have it ready. I made it ready for this. Whether I
7 filed it then or after, I'm not sure.
8 Q Did you file after the closing?
9 A I'm not sure. I know that I had to create
10 -- I had to do the taxes earlier for Mr. Cannone.
11 Q This is for 2013. So I will show you
12 Deposition Exhibit Number 27. You have previously
13 testified you prepared that?
14 A Yes.
15 Q You arrived at those numbers on the basis of
16 deposits that you had made, the rent roll and your
17 memory, correct?
18 A My knowledge.
19 Q Exhibit 27, was that included in your 2013
20 return that you filed?
21 A I think so.
22 Q So there was no difference between the
23 Schedule E that you provided Mr. Cannone, a copy
24 with that, and the one that you submitted as part of
25 the final return which was filed with the Internal
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Adang
2 Revenue Service?
3 A I don't think so.
4 Q So the income reflected on Schedule E in the
5 file with the return for 2013 would be $172,000?
6 A I think so.
7 Q You also testified earlier that you
8 deposited cash receipts from the operation of the
9 mobile home park into the money market account
10 because it got a higher rate of interest, is that
11 correct?
12 A Yes.
13 Q You looked at all of the deposits for the
14 Bluebird Terrace Mobile Home Park for 2011, 2012 and
15 2013, is that correct? You looked at those today.
16 You identified those?
17 A They were incomplete. I had noted they were
18 incomplete. I looked at what you showed me.
19 Q Incomplete in what sense?
20 A On deposit slips, it says there were checks.
21 They weren't there underneath the deposit slips. I
22 couldn't see them.
23 Q There was a lot of cash deposited in 2011
24 and 2012 in the Bluebird Terrace Mobile Home Park,
25 is that not a fair statement?
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. 68 RECEIVED NYSCEF: 06/23/2022
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1 Zaharah Badrudin - Atty. Adang
2 A I don't know a lot of cash. There was cash
3 there.
4 Q Thousands of dollars deposited in 2011 and
5 2012?
6 A I think it was over a thousand, yes.
7 Q Thousands of dollars?
8 A Over 2,000 I would say, yes.
9
Preview
FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 06/23/2022 261 1 Zaharah Badrudin - S. Badrudin 2 else? 3 A He would tell me. The Town would tell me. 4 New York State inspector told me. In fact, he 5 showed me a log of all the times he went. It's a 6 small town. People tell each other. 7 Q Did you give him permission? 8 A I understood it was part of his due 9 diligence so I didn't give him permission. I didn't 10 tell him he couldn't but -- didn't tell him he 11 couldn't. 12 Q More than a year of due diligence? 13 A I know he went to the Town. I know he 14 started going to the Town before we ever signed this 15 contract that was signed in March 14, 2014. I know 16 he was already talking to the Town at that time. 17 MR. ADANG: I object to the form of 18 the question. 19 Q So how long did you think due diligence 20 would last? 21 A I wasn't sure how long it would last. 22 Q How long did his last? 23 A His due diligence started before he entered into -- before the date of March 2014 when we 24 14, 25 signed this agreement for purchase and sale of real STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - (518) 6832 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 06/23/2022 262 1 Zaharah Badrudin - S. Badrudin 2 estate. It had already started because as part of 3 this contract, we included letters from the Town and -- 4 different issues that were already part of 5 because we started the due diligence when we met 6 which was at the end of 2013 beginning of 2014. 7 Q Approximately how many months is that? 8 A About -- I couldn't for approximately say 9 sure. More than -- it was -- I couldn't for say sure but would it was at least -- more than 10 I say 11 five months. 12 Q When he went to the park, did he do any 13 work? 14 A Yes; he dug up all the septic systems. So I 15 showed him where all the septic systems were. So he 16 brought two people with him. They dug it up and 17 looked at it. But, no, he did a lot of 18 drive-throughs, spoke to a lot of people, commented 19 on snow removal, grass, what he would do to improve 20 it. 21 Q Do you remember if he dug up all the septic 22 systems before or after the agreement was signed? 23 A I think it was after. 24 Q Did he do any work before the agreement? 25 A He went to the Town before the agreement and 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. 68 RECEIVED NYSCEF: 06/23/2022 263 1 Zaharah Badrudin - S. Badrudin 2 the Health Department and the Town and Health 3 Department. 4 MR. ADANG: I'm going to object to 5 the form of the question. 6 Q Was any work done by him? Do you know of 7 anything done by him before the agreement was 8 signed? 9 A Yes. I know he went to the town and spoke 10 to the inspectors. 11 MR. ADANG: Object to the form of 12 the question. You can answer. 13 Q I will rephrase. 14 MR. ADANG: We are off the record. 15 (An off-the-record discussion was had.) 16 Q What specifically did he do before this 17 agreement was signed? 18 A He went to the Town and spoke to the 19 inspectors. We spoke at length, me and him. And we met also multiple times. He collected -- he 20 asked 21 for information from me I think regarding who paid, 22 how much, were trailers owned by us or owned by 23 residents. He went to New York State Department of 24 Health to see if we had outstanding violations, if 25 our permit was okay. He went to the Town of Moreau STEPHANIE PICOZZI, CRR, RPR Martin Deposition Services, Inc. 587 - (518) 6832 FILED: SARATOGA COUNTY CLERK 06/23/2022 05:44 PM INDEX NO. EF20212538 NYSCEF DOC. NO. 68 RECEIVED NYSCEF: 06/23/2022 264 1 Zaharah Badrudin - S. Badrudin 2 to do the same. And I believe he also in the same went and made sure that our -- he 3 building looked at 4 our school and property tax and water bills. 5 Q Did he go anywhere else? 6 A Yes; he went to the park. He drove around 7 the park. He spoke to people. 8 Q Any other institutions? 9 MR. ADANG: Are you asking a 10 question? 11 MS. S. BADRUDIN: Yes. 12 MR. ADANG: Ask it so we can hear 13 it. Let her finish the answer to your 14 first question. 15 Are you finished? 16 THE WITNESS: Yes. 17 MR. ADANG: Now you can ask another 18 question. 19 Q Any other institutions? 20 A Yes. He went to the company that pumps our 21 septic system and inquired about the pumping 22 records. I believe he followed up on information in 23 our Department of Health file regarding our engineer 24 but I'm not sure of that. I do know he went to the place where -- our to inquire 25 pumping company 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. 68 RECEIVED NYSCEF: 06/23/2022 265 1 Zaharah Badrudin - S. Badrudin 2 because he told me and they told me as well. 3 Q How did you feel about that? 4 A Well, I felt like at least he was doing his 5 due diligence. I felt like I wanted to do whatever 6 I could to give him as much information, whatever he 7 asked for, so that he has the full picture. 8 Q What did he ask for? 9 A He asked for the rent, who was paying how 10 much, which ones were vacant, which ones were owned 11 by us, which were owned by people in the park. 12 Information regarding the STAR rebate program. 13 Information the work -- had some regarding we 14 outstanding issues with the Town regarding condemned 15 properties and our plan how we will fix it. He 16 asked for the taxes. 17 Q What did you tell him about the taxes? 18 A I told him that I was missing one of the 19 years and he said that it would be fine. And I told 20 him I didn't have 2013 done yet. I hadn't filed it 21 because I file in October. And he said, "just do 22 the section that pertains to us and give that to me income." 23 because I need it to verify 24 Q Were you certain that he was going to be 25 buying the 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. 68 RECEIVED NYSCEF: 06/23/2022 266 1 Zaharah Badrudin - S. Badrudin 2 A No. He was asking so many questions. They 3 kept delaying the closing date. They delayed it 4 multiple times because I think they were looking for 5 more information or he didn't get the mortgage. 6 There was an issue he had. And I wasn't sure that 7 it was going to go through and that made me angry 8 because he told everybody and people stopped paying 9 me. 10 Q Do you know approximately how many times 11 they delayed it? 12 A At least twice. And they kept asking for 13 more information. 14 Q Do you know the time frame, how long? A think -- 15 I 16 Q Do you know the time frame? A think -- couldn't be 17 I the first I sure but 18 I think it was moved twice in May and June but I'm 19 not sure. 20 Q Did you know if you could sell the property? 21 A I thought I could sell the property because 22 of the deeds. 23 Q So who did you think was the owner of the 24 park? 25 A Salimah Badrudin. 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. 68 RECEIVED NYSCEF: 06/23/2022 267 1 Zaharah Badrudin - S. Badrudin 2 Q So you thought she can sell the property? 3 A Yes. 4 MS. EVERHART: Object to form of the 5 last question. 6 To clarify for the record, Salimah 7 Badrudin is present and is the person 8 asking questions here as a pro se witness, 9 not as an attorney. 10 Go ahead. 11 Q So did you know if Salimah wanted to sell 12 the property? 13 MR. ADANG: It's the same objection. 14 Q Do you know Ms. Koolsam? 15 A Yes. 16 Q What's her story? 17 MR. ADANG: I will object to the 18 form of the question. 19 Q What do you know about her? A know that first heard she came on -- she 20 I I 21 put in a claim in my dad's estate in 2009 I think, about -- she was dad's 22 not sure, saying that my 23 divorced ex-wife. She had given a child support -- 24 order. She was saying she ran could not find my 25 father for years because she could not find him 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. 68 RECEIVED NYSCEF: 06/23/2022 268 1 Zaharah Badrudin - S. Badrudin 2 based on his last name. She didn't know the last 3 name. It wasn't her married name. And so she said 4 all that under oath. 5 In 2013 she said, "hold on a second. Hold 6 on a second. I was looking for him. He is my husband. never -- 7 I was able to get married never 8 able to get married because I could not find him and him." 9 I was married to And so that was her story. 10 She was saying, "I am the wife. I am Yasmin Badrudin." -- 11 The name she said she didn't know 12 Badrudin is the name that she claims to be and then 13 she changed her name to Yasmin K. Badrudin after I 14 think it was 40 years since her marriage, in 40 15 years since she saw him last and said she wants to 16 put in a claim for -- I think to she was married say 17 to my dad. But she was married to my dad. And so 18 this, I think, happened in 2013. And since then, 19 she has been representing herself as Yasmin 20 Badrudin. 21 Q Did she do any work in the park? A -- don't think ever met 22 No. We have not I I 23 her until I saw her in court in 2009. 24 Q Did you talk to anyone else about selling 25 the park? 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. 68 RECEIVED NYSCEF: 06/23/2022 269 1 Zaharah Badrudin - Atty. Adang 2 A Did I talk to anyone about selling it? Who 3 are you referring to as "anyone"? 4 Q Any attorneys? 5 A About whether I could sell or about selling 6 the park? 7 Q Either. 8 A Okay. About whether I could sell, yes. I 9 spoke to multiple attorneys in my phone 10 conversations and I understood it to mean that if 11 the deed was because my dad had given it to my mom, 12 it was valid and we could record it and sell it. 13 And did I talk to any attorneys regarding the sale? 14 I don't remember specifically talking to any 15 attorneys. 16 Q Just to clarify, what information did you 17 give Mr. Cannone? A gave him -- 18 I 19 MR. ADANG: I will object to the 20 form of that question. I think that's been 21 asked and answered on multiple occasions. 22 MS. S. BADRUDIN: That's all I have. 23 EXAMINATION 24 BY MR. ADANG: 25 Q Ms. Badrudin, you just testified that 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. 68 RECEIVED NYSCEF: 06/23/2022 270 1 Zaharah Badrudin - Atty. Adang 2 spoke to attorneys about whether or not you could 3 sell the mobile home park? 4 A It's about what I could do with the deed. I think -- 5 Q 6 A That's what I meant, what I could do with 7 the deed. 8 Q Salimah Badrudin asked you if you had spoken 9 to attorneys about whether you could sell the mobile 10 home park. I believe your testimony was that you 11 did speak to attorneys about whether or not you 12 could sell it. 13 A I was referencing what to do with the deed, 14 the same scenario I previously talked about, the 15 same situation. 16 Q I think those are two different situations. 17 A I understood the question to mean that. I'm 18 sorry. 19 Q Understood whose question? 20 A My sister's question to mean what process 21 did you take with these deeds. That's the question 22 I was answering. 23 Q She didn't ask what process you went 24 through. She asked you if you spoke to attorneys 25 about whether or not you could sell the property. 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. 68 RECEIVED NYSCEF: 06/23/2022 271 1 Zaharah Badrudin - At . ty Adang 2 My question is, why would you speak with 3 attorneys about whether or not you could sell the 4 property when you testified earlier it was your 5 belief that your sister owned the property? A -- when that 6 Right, so I was saying earlier 7 in response to my sister's question, I was referring 8 . to what to do with the deeds and that's when I 9 understood that they were her property which means 10 she could sell. That's what I responded as I wasn't 11 -- so that's where got could sell I from. They are 12 her property. That's how I went back to the deeds 13 in my mind. 14 Sorry if I didn't answer the question the 15 way it was intended. I answered it the way I 16 understood her question to mean. 17 Q You testified earlier that Mr. Cannone asked 18 you to provide him with Schedule E to the 2000 19 return prior to the closing, is that correct? 20 A Yes. 21 Q And I believe your testimony was that you 22 advised him that the return had not been filed at that point -- 23 24 A Yes. -- that correct? 25 Q is 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. 68 RECEIVED NYSCEF: 06/23/2022 272 1 Zaharah Badrudin - Atty. Adang 2 It was also your testimony that you filed 3 the return in October of 2014 after the closing? 4 A I think I said that is when I normally file. 5 I didn't have it ready at the time. So I didn't 6 have it ready. I made it ready for this. Whether I 7 filed it then or after, I'm not sure. 8 Q Did you file after the closing? 9 A I'm not sure. I know that I had to create 10 -- I had to do the taxes earlier for Mr. Cannone. 11 Q This is for 2013. So I will show you 12 Deposition Exhibit Number 27. You have previously 13 testified you prepared that? 14 A Yes. 15 Q You arrived at those numbers on the basis of 16 deposits that you had made, the rent roll and your 17 memory, correct? 18 A My knowledge. 19 Q Exhibit 27, was that included in your 2013 20 return that you filed? 21 A I think so. 22 Q So there was no difference between the 23 Schedule E that you provided Mr. Cannone, a copy 24 with that, and the one that you submitted as part of 25 the final return which was filed with the Internal 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. 68 RECEIVED NYSCEF: 06/23/2022 273 1 Zaharah Badrudin - Atty. Adang 2 Revenue Service? 3 A I don't think so. 4 Q So the income reflected on Schedule E in the 5 file with the return for 2013 would be $172,000? 6 A I think so. 7 Q You also testified earlier that you 8 deposited cash receipts from the operation of the 9 mobile home park into the money market account 10 because it got a higher rate of interest, is that 11 correct? 12 A Yes. 13 Q You looked at all of the deposits for the 14 Bluebird Terrace Mobile Home Park for 2011, 2012 and 15 2013, is that correct? You looked at those today. 16 You identified those? 17 A They were incomplete. I had noted they were 18 incomplete. I looked at what you showed me. 19 Q Incomplete in what sense? 20 A On deposit slips, it says there were checks. 21 They weren't there underneath the deposit slips. I 22 couldn't see them. 23 Q There was a lot of cash deposited in 2011 24 and 2012 in the Bluebird Terrace Mobile Home Park, 25 is that not a fair statement? 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. 68 RECEIVED NYSCEF: 06/23/2022 274 1 Zaharah Badrudin - Atty. Adang 2 A I don't know a lot of cash. There was cash 3 there. 4 Q Thousands of dollars deposited in 2011 and 5 2012? 6 A I think it was over a thousand, yes. 7 Q Thousands of dollars? 8 A Over 2,000 I would say, yes. 9