Preview
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
"11"
Exhibit
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
Page 348
1 SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
2
3
4
5 MUNIR SEEN,
6 Plaintiff,
7
-against-
8
A. W. CHESTERTON COMPANY, et al. ,
9
De fendants .
10
11
12
13
DEPOSITION UNDER ORAL
14 EXAMINATION OF
MUNIR SEEN
15
VOLUME II
16
17
18
19
20
21
22
23
24 INDEX NO.: 190225/2018
25 Job No. NJ3281113
Priority-One Court Services Inc.- A Veritext
Reporting Company
718-983-1234
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
Page 349 Page351
1 Transcript
of the deposition
of the
2 I MONSHANLY CONROT
2 witness, for
called Oral Examination in the 112MadisonAvenue,7thFloor
3 New York, NewYork 10012
3 above-caationed said deposition
matter, being taken Attomeysfor thePlaintiff
4 pursuantto Federal
Rules of Civil
Procedureby and 4 BY: DANIEL BLOUIN, ESQ.
5 B JAMESCONUS ESQ
5 beforeDORENE GREGORIO, CSR, a NotaryPublic
6 and Certified
ShorthandReporter,at the home of the 6
7 40 Lupton
Plaintiff, Lane,apartmentA, Haledon,New
FORMAN,WATKINS & KRUTZ, LLP
8 Jersey on Friday,
March 15, 2019,
commencing at 8 328NewmanSpringsRoad
. RedBank,New Jersey07701
9 approximately12:06 m the afternoon' 9 Attorneysfor Defendants,Inte-sti=:'
Paper,
10 Weyerhaeuser
Company
10 BY: MATTHEW BRODERSON,ESQ.
1I
12 12 MALABY & BRADLEY, LLC
150Broadway,Suite600
13 13 NewYork, NewYork 10038
]4 Attorneysfor Defendant,McKessonCorporation
14 BY: DAVID H. JONES,ESQ.
15 15
]6 16 McGIVNEY KLUGER& COOK,P.C.
80BroadStreet,23rdFloor
17 17 New York, NewYork 10004
18 Attomeysfor Defendant,IPA
18 BY: GARY CASIMIR,ESQ.
19 19
20 20 BOROWSKY& BOROWSKY,LLC
59 Avenueatthe Common,Suite101and102
21 21 Shrewsbury,NewJersey07702
22 Attorneysfor Defendant,SimpsonTimberCompany
22 BY: MICHAEL A. FIELD, ESQ.
23 (VIA TELECONFERENCE)
24 23
24
25 25
Page350 Page 352
1 A PP E A R A N C E S
1 IT IS HEREBYSTIPULATEDAND AGREEDby andbetween
2 GORDON& REESSCULLY MANSUKHANI, LLP
2 theattomeysfor therespectivepartiesheretothat 101W. Broadway,Suite2000
3 SanDiego,CA 92101
3 filing, sealingandcertificationof thewithin Attomeysfor Defendant,Conwed
4 ExaminationBeforeTrial be waived;thatall objections, 4 A SQ
5 exceptasto form, arereservedto thetimeof tnal. 5
6
6
WATERS,McPHERSON,McNEILL, P.C.
7 IT IS FURTHERSTIPULATEDAND AGREEDthatthe 7 300LightingWay
New Jersey070%
Secaucus,
8 transcriptmaybesignedbeforeanyNotary 8 Attomeysfor Defendant,TurnerConstruction
9 Publicwith thesameforceandeffectasifsigned BY: ROBERTLIPSCHITZ,ESQ.
9 (VIA TELECONFERENCE)
10 beforeaClerkor Judgeof theCourt. 10
11 RENZULLI LAW, LLP
OneNorth Broadway,Suite1005
12 IT IS FURTHERSTIPULATEDAND AGREEDthatthewithin 12 White Plains,NewYork 10601
Attomeysfor Defendant,Pfizer
13 examinationmaybeutilizedfor all purposesasprovided 13 BY: JUSTINSHANE,ESQ.
14 by theCPLR. EMW
15 15
GIBBONS,P.C.
16 IT IS FURTHERSTIPULATEDAND AGREEDthatall rights (6 OneGatewayCenter
17 providedto all partiesby theCPLRshallnotbedeemed Newark,New Jersey07102
17 Attorneysfor Defendant,
18 waivedandtheappropriatesectionsof theCPLRshallbe TheSherwin-WilliamsCompany
19 controllingwith respectthereto. 18 BY: ROBERTD. BROWN,JR., ESQ.
(VIA TELECONFERENCE)
20 19
20
21 IT IS FURTHERSTIPULATEDAND AGREEDby andbetween 21
22 theattorneysfor therespectivepartiesheretothata 22
A L SO PR ESEN T
23 copyof this Examinationshallbe furnished,without 23
24 charge,to the attorneyrepresenting
thewitness
24
25 testifyingherein. 25
2 (Pages 349 -
352)
Priority-One Court Services Inc. - A Veritext
Reporting Company
718-983-1234
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
Page353 Page355
1 INDEX 1 A. Yes, sir.
2 WITNESS NAME PAGE NO. 2 Q. And who did youmarry on October20, 2018?
3 MUNIR SEEN 3 A. Rwida Basha.
4 4 Q. How do you spell
her name, please?
5 Direct Examination by MR. CASIMIR 354 5 A. R-W-I-D-A.
6 6 Q. D-A?
7 7 A. Yes. And the last name is Basha.
That's
8 8 B-A-S-H-A.
9 9 Q. Is that her maiden
name, Rwida Basha?
10 10 A. Yes.
I I 1I Q. Has she now takenon the name RwidaBasha Seen?
12 12 A. No.
13 13 Q. Where was yourwedding?
14 14 A. It's
in the mosque.
15 15 Q. Is that the mosque at the Islamic
located Center
16 16 of UnionCounty?
17 17 A. Yes, sir.
18 18 Q. Who was presentat your
marriage?
19 19 A. My son and her daughter
and my friend.
20 20 Q. I know yourson, is it Sineer
(phonetic)?
21 21 A. Sinar.
22 22 Q. Sinar?
23 23 A. Yes.
24 24 Q. And your daughteris?
25 25 A. Sirsa.
Page354 Page356
1 M UN I R S E E N, I Q. How do you spellthat?
2 Calledas a witness,
having been first
dulysworn by 2 A. S-I-R-S-A.
3 aNotary PublicoftheStateof New York, was 3 Q. Now, which friend was present?
4 examined and testified
as follows: 4 A. It's
a family friend.
5 EXAMINATION BY 5 Q. What is yourfriend'sname, please?
6 MR. CASIMIR: 6 A. Abdalla.
7 Q. Good Mr.
afternoon, Seen. Let me know if I am 7 Q. Abdalla?
8 pronouncingyour Is it Seen?
name correctly. 8 A. Yes, Odeh.
9 A. Yes, sir. 9 Q. How do you spellthe lastname?
10 Q. Okay, Good afternoon,Mr. Seen. 10 A. O-D-E-H.
11 A. Good afternoon. 11 Q. Okay. Now, withreference to yourmarriage to
12 Q. My name is GaryCasimir,and we're going
to do a 12 Ms. Basha, was therean engagement priorto the
13 very limited
short, discoverydeposition.It's going
to 13 marriage?
14 marriage
focus on your and what has been filed
as an 14 A. No.
15 economic in this case, okay?
report 15 Q. Priortothe marriage toMs. Basha, didyou live
16 A. Okay. 16 together?
17 Q. The first
thingI want sir, are you
to ask you, 17 A. No.
18 married?
currently 18 Q. When did you first
meet Ms. Basha?
19 A. Yes. 19 A. Oh, a year-and-a-half ago.
20 Q. During yourprior do you recall
deposition, if 20 Q. Priorto your marriage toMs. Basha, was she
2I you were marriedthen? 21 aware of your current conditicñ?
22 A. No. 22 A. Justbefore we got married, yes. Not when we
23 Q. When were youmarried? 23 met.
24 A. October 20th. 24 Q. Was Ms. Basha ever previouslymarried?
25 Q. Is that October
20, 2018? 25 A. Oh, yeah.
3 (Pages 353 -
356)
Priority-One Court Services Inc. - A Veritext
Reporting Company
718-983-1234
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
Page 357 Page359
I Q. Who was she previously
marriedto? 1 Ms. Basha?
2 A. I have no idea. 2 A. November 2018.
3 Q. Do you know when Ms. Basha obtainedher divorce 3 Q. You indicated
that.So was Ms. Basha living
here
4 frorn
her last marriage? 4 in November
starting 2018?
5 A. Yes. 5 A. Yes.
6 Q. When was that? 6 Q. And at that time
were you in a different
living
7 A. June 5th, 2018. 7 location
yourself?
8 Q. Where did Ms. husband
Basha and her previous 8 A. Yes.
9 live? 9 Q. Where wereyou living?
10 A. Haledon. 10 A. 1412 Summer HillRoad, Wayne,New Jersey.
11 Q. Here? 11 Q. Previousto yourmarriageto Basha, were you
12 A. Yes. 12 married?
13 MR. CASIMIR: Let the record that we
reflect 13 A. No.
14 are currently
at, I think,
40 Lupton -- 14 Q. I'm sorry.Letme rephrase that question.
How
15 THE WITNESS: No, no. 15 many timeshave you been marriedall together?
16 MR. CASIMIR: No? 16 MR. BLOUIN: That was coveredin the first
17 THE WITNESS: No. They didn'tlivehere. 17 deposition.
18 They livedin this town. 18 MR. CASIMIR: I understand to
It's going
19 MR. CASIMIR: Oh, in this complex? 19 lead to a question
that's related
to this inquiry.
20 THE WITNESS: In this town. 20 Q. How many times were youmarriedbeforeall
21 MR. CASIMIR: In this town? 21 together?
22 THE WITNESS: Not the complex,not this 22 A. Three times.
23 apartment. 23 Q. Three timesall together?
24 MR. CASIMIR: But in Haldale? 24 A. Yes.
25 THE WITNESS: Haledon. I'msorry,I cannot 25 Q. And your last wife,
based on your
previous
Page358 Page360
1 speak too loud,okay. 1 deposition,was Inam Idris?
2 MR. CASIMIR: No problem. Ifat anytime 2 A. Yes.
3 you need to take a break,we can take a break.I'n 3 Q. Did you obtain a divorcefrom Inam Idris?
4 justtryingtomove as quickly as possible,okay? 4 A. Yes.
5 THE WITNESS: Okay. 5 Q. Prior tothat,what yeardid you obtain the
6 6 divorce from Ms. Idris?
7 CONTINUED EXAMINATION BY 7 A. No idea.
8 MR. CASIMIR: 8 Q. Okay. Priortothat,were you married to Hana
9 Q. Allright.Now, I understand thatyou were 9 Mamkegh?
10 married at theIslamicCenter inUnion County? 10 A. Mamkegh.
I1 A. Yes. 11 Q. Can you spellthat lastname, please?
12 Q. Did you alsogo to Hall -- 12 A. It's
hard for me also.
City
13 A. No. 13 Q. It's
hard for you also.
14 Q. -- toobtain a marriage license? 14 A. Yes.
15 A. No. 15 Q. Go ahead.
16 Q. Do you and Basha currentlylivetogetherinthir 16 A. M-A-M-K-E-G-H.
17 home? 17 MR. CASIMIR: Can the courtreporter pleas¤
18 A. Yes. 18 read back the spelling.
19 Q. Was this Basha'shome -- 19 (Whereupon the referred-to
answer was read
20 A. No. 20 back by the court reporter.)
21 Q. --prior toyour marriage? 21 Q. Is that
correct,what the courtreporterjust
22 A. No. 22 read back?
23 Q. Whose home was thisprior toyour marriage? 23 A. Yes.
24 A. I have no idea.We justrentit. 24 Q. Can you pleasespell herfirstname?
25 Q. When did you first
startrenting thishome with 25 A. H-A-N-A.
4 (Pages 357 -
360)
Priority-One Court Services Inc. - A Veritext
Reporting Company
718-983-1234
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
Page361 Page363
1 Q. Just one "N"? I minutes,and I think
that youwillsee whereit's
2 A. Yes. 2 going.
3 Q. Is this her maiden
name? 3 MR. BLOUIN: No, I don't
want to wait.
I
4 A. Yes. 4 don'twant youto --
5 Q. Did she ever take your
name on, Seen? 5 MR. CASIMIR: Well,I'm goingto ask the
6 A. No. 6 and you
question, can direct
him not to answer it.
7 Q. Where were you two married? 7 That'show it works.Okay? I understand
what
you'
8 A. Jordan. 8 e saying,but --
9 Q. Jordan? 9 MR. BLOUIN: Or maybe we willjustshut the
10 A. Yes. 10 depositiondown and do the video,
because we had an
II Q. When you came here in '67 or '68, did
she come 11 agreement are now
that you breaking.
12 here withyou -- 12 MR. CASIMIR: Ifyou feel sensitive
about
13 A. No. 13 whateveryou thinkI'm breakingbecause youare not
14 Q. -- or did
she come here after? 14 seeingthebiggerpicture,that's toyou,
up
15 A. No, she came here after. 15 counselor.
16 Q. What year didMs. Mamkegh -- I apologize
that I 16 MR. BLOUIN: What is the bigger
pictue?
17 can't say her name.
What year didHana come? 17 Why don't
you tellme.
18 A, Late '70s. 18 MR. CASIMIR: Let me ask the questions
and
19 Q. '70s? 19 you'll
see.
20 A. Late '70s. 20 MR. BLOUIN: I wantan offer
of proofor the
21 Q. You have two childrenwithHana, forshort, 21 deposition's
done.
22 correct? 22 MR. CASIMIR: I'm just
goingto ask him
23 A. Yes. 23 simplequestionsabout where theylived
and when
24 Q. When you weremarried to Hana,where did youlive 24 theygot divorced.I'm allowed
totally toask
25 withher? 25 those questions.
Page362 Page364
1 A. United States and Jordan.
Backand forthbetween 1 MR. BLOUIN: No, you'renot, because you
2 U.S.and Jordan. 2 have broken
basically another agreementwithme.
3 Q. Did you ever live
in New Jersey with
her? 3 MR. CASIMIR: I don't
have any other
4 A. Yes. 4 agreement withyou. Thisis the only
timewe've
5 Q. Where did you with
live her in NewJersey? 5 talkedaboutit.
6 A. I don't
know. We kept moving from one apâitmcñt 6 MR. BLOUIN: It's in the e-mails.
in writing
7 to the another,
so... 7 MR. CASIMIR: I intend
to ask about his
8 Q, Can you justgiveme the general
towns, locations 8 marriages, to --
and I intend
9 or counties? 9 MR. BLOUIN: No, not about his marriages,
10 A. Okay. Passaic Countymostly. 10 about his new marriage.
Okay, deposition
over.
1I Q. Passaic? 11 Let's take the video.
12 A. Yes. 12 MR. CASIMIR: Dan, calmdown.
13 Q. You had two childrenwithher in the United 13 MR. BLOUIN: Let's take the video.
14 States? 14 MR. CASIMIR: Calm down.
15 A. Yes. 15 MR. BLOUIN: Ifyou have a problem,
you can
I6 MR. BLOUIN: Okay. This was all covered
in 16 callthe special
master. We're doingthe video
in
17 the first
deposition.I'mnot letting
him answer 17 the meantime.
18 any more questions
about anythingthat was outside 18 MR. CASIMIR: I have 30 minutes.
Do you
19 of the topics
that we agreed upon to go forward
in 19 want me to do the 30 minutes?
20 this deposition.
This all covered
is literally in 20 MR. BLOUIN: No, you don't get a 30-minute
21 the first
deposition.You said that we're
goingto 21 depositionabout whateva you see fit.
22 talkabout his marriage
and economicsafter 22 MR. CASIMIR: Dan, you'reright
now breaking
23 marriage,his new marriage
and nothingelse.This 23 down over one question.
The answer is --
24 is not going
anywhere that can be articulated. 24 MR. BLOUIN: No, you --
asked 20 question
25 MR. CASIMIR: I'malmost done in two 25 MR. CASIMIR: -- youdon'tanswer the
5 (Pages 361 -
364)
Priority-One Court Services Inc. - A Veritext
Reporting Company
718-983-1234
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018
NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019
Page365 Page367
1 questionand then we moveon to somethingelse. I was previouslycovered. I have the depositicñ
2 You don'thave a nuclear
incidentbecause youdon't 2 transcript.
3 likea question.
You say, no, I'm
not goingto let 3 Q. Did you get a divorce
fromHana in New Jersey?
4 him answer andmove on toanotherquestion. 4 MR. BLOUIN: You don'tneed to answer that
5 MR. BLOUIN: I'mnot -- he has been 5 question.
6 questionsfor the past five
minutes -- 6 Q. Do you recallthe county
in whichthe divorce
answering
7 I've been watching --
the clock 7 was filed?
8 MR. CASIMIR: Right. 8 MR. BLOUIN: Allof this
could have been
9 MR. BLOUIN: -- aboutstuff
outsideof what 9 coveredin the Defendant's deposition.
discovery
10 you agreed to ask questions
about. 10 Objection.
11 MR. CASIMIR: I understand
you thinkit's 1I You don'tneed to answerthis question.
12 but you're
outside, making a claim
for spousal 12 MR. CASIMIR: Counsel is blocking
questions
13 support.There are issues there.
I don't
have to 13 relevantto his current
claimofa new marriage
14 teach youhow to do this.
I knowyou know. I'm 14 I'm
and, therefore, going to seek a motion
to bring
15 goingto coverthis area.
It maylead to nothing. 15 back the witness
and ask any and all relevant
16 It is a discovery
deposition.I am entitled
to ask 16 questionsto the new claim
concerñinga more recent
17 these questions.
I understand
you feel -- 17 marriage.
18 MR. BLOUIN: About marriages?
his previous 18 So let's just
move on to the ecenemic
report
19 MR. CASIMIR: Yes. They to
are important 19 at this time.
20 the -- yes.
They coverissues, Dan. 20 Q. Mr. familiar
Seen, are you at all with
an
21 MR. BLOUIN: No, theydo not. 21 economic reportthat your
attorneyhas filed
on your
22 MR. CASIMIR: You can ask -- 22 behalf?
23 MR. BLOUIN: No, that's not what
we agreed 23 A. Yes.
24 upon. 24 MR. BLOUIN: Have you seen an economic
25 MR. CASIMIR: You can justblockthe 25 report?
Page366 Page368
1 questionand we willmove on to the next
one. It's 1 THE WITNESS: No.
2 okay.
perfectly I will
make a motionto bring
Preview
FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 "11" Exhibit FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 Page 348 1 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK 2 3 4 5 MUNIR SEEN, 6 Plaintiff, 7 -against- 8 A. W. CHESTERTON COMPANY, et al. , 9 De fendants . 10 11 12 13 DEPOSITION UNDER ORAL 14 EXAMINATION OF MUNIR SEEN 15 VOLUME II 16 17 18 19 20 21 22 23 24 INDEX NO.: 190225/2018 25 Job No. NJ3281113 Priority-One Court Services Inc.- A Veritext Reporting Company 718-983-1234 FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 Page 349 Page351 1 Transcript of the deposition of the 2 I MONSHANLY CONROT 2 witness, for called Oral Examination in the 112MadisonAvenue,7thFloor 3 New York, NewYork 10012 3 above-caationed said deposition matter, being taken Attomeysfor thePlaintiff 4 pursuantto Federal Rules of Civil Procedureby and 4 BY: DANIEL BLOUIN, ESQ. 5 B JAMESCONUS ESQ 5 beforeDORENE GREGORIO, CSR, a NotaryPublic 6 and Certified ShorthandReporter,at the home of the 6 7 40 Lupton Plaintiff, Lane,apartmentA, Haledon,New FORMAN,WATKINS & KRUTZ, LLP 8 Jersey on Friday, March 15, 2019, commencing at 8 328NewmanSpringsRoad . RedBank,New Jersey07701 9 approximately12:06 m the afternoon' 9 Attorneysfor Defendants,Inte-sti=:' Paper, 10 Weyerhaeuser Company 10 BY: MATTHEW BRODERSON,ESQ. 1I 12 12 MALABY & BRADLEY, LLC 150Broadway,Suite600 13 13 NewYork, NewYork 10038 ]4 Attorneysfor Defendant,McKessonCorporation 14 BY: DAVID H. JONES,ESQ. 15 15 ]6 16 McGIVNEY KLUGER& COOK,P.C. 80BroadStreet,23rdFloor 17 17 New York, NewYork 10004 18 Attomeysfor Defendant,IPA 18 BY: GARY CASIMIR,ESQ. 19 19 20 20 BOROWSKY& BOROWSKY,LLC 59 Avenueatthe Common,Suite101and102 21 21 Shrewsbury,NewJersey07702 22 Attorneysfor Defendant,SimpsonTimberCompany 22 BY: MICHAEL A. FIELD, ESQ. 23 (VIA TELECONFERENCE) 24 23 24 25 25 Page350 Page 352 1 A PP E A R A N C E S 1 IT IS HEREBYSTIPULATEDAND AGREEDby andbetween 2 GORDON& REESSCULLY MANSUKHANI, LLP 2 theattomeysfor therespectivepartiesheretothat 101W. Broadway,Suite2000 3 SanDiego,CA 92101 3 filing, sealingandcertificationof thewithin Attomeysfor Defendant,Conwed 4 ExaminationBeforeTrial be waived;thatall objections, 4 A SQ 5 exceptasto form, arereservedto thetimeof tnal. 5 6 6 WATERS,McPHERSON,McNEILL, P.C. 7 IT IS FURTHERSTIPULATEDAND AGREEDthatthe 7 300LightingWay New Jersey070% Secaucus, 8 transcriptmaybesignedbeforeanyNotary 8 Attomeysfor Defendant,TurnerConstruction 9 Publicwith thesameforceandeffectasifsigned BY: ROBERTLIPSCHITZ,ESQ. 9 (VIA TELECONFERENCE) 10 beforeaClerkor Judgeof theCourt. 10 11 RENZULLI LAW, LLP OneNorth Broadway,Suite1005 12 IT IS FURTHERSTIPULATEDAND AGREEDthatthewithin 12 White Plains,NewYork 10601 Attomeysfor Defendant,Pfizer 13 examinationmaybeutilizedfor all purposesasprovided 13 BY: JUSTINSHANE,ESQ. 14 by theCPLR. EMW 15 15 GIBBONS,P.C. 16 IT IS FURTHERSTIPULATEDAND AGREEDthatall rights (6 OneGatewayCenter 17 providedto all partiesby theCPLRshallnotbedeemed Newark,New Jersey07102 17 Attorneysfor Defendant, 18 waivedandtheappropriatesectionsof theCPLRshallbe TheSherwin-WilliamsCompany 19 controllingwith respectthereto. 18 BY: ROBERTD. BROWN,JR., ESQ. (VIA TELECONFERENCE) 20 19 20 21 IT IS FURTHERSTIPULATEDAND AGREEDby andbetween 21 22 theattorneysfor therespectivepartiesheretothata 22 A L SO PR ESEN T 23 copyof this Examinationshallbe furnished,without 23 24 charge,to the attorneyrepresenting thewitness 24 25 testifyingherein. 25 2 (Pages 349 - 352) Priority-One Court Services Inc. - A Veritext Reporting Company 718-983-1234 FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 Page353 Page355 1 INDEX 1 A. Yes, sir. 2 WITNESS NAME PAGE NO. 2 Q. And who did youmarry on October20, 2018? 3 MUNIR SEEN 3 A. Rwida Basha. 4 4 Q. How do you spell her name, please? 5 Direct Examination by MR. CASIMIR 354 5 A. R-W-I-D-A. 6 6 Q. D-A? 7 7 A. Yes. And the last name is Basha. That's 8 8 B-A-S-H-A. 9 9 Q. Is that her maiden name, Rwida Basha? 10 10 A. Yes. I I 1I Q. Has she now takenon the name RwidaBasha Seen? 12 12 A. No. 13 13 Q. Where was yourwedding? 14 14 A. It's in the mosque. 15 15 Q. Is that the mosque at the Islamic located Center 16 16 of UnionCounty? 17 17 A. Yes, sir. 18 18 Q. Who was presentat your marriage? 19 19 A. My son and her daughter and my friend. 20 20 Q. I know yourson, is it Sineer (phonetic)? 21 21 A. Sinar. 22 22 Q. Sinar? 23 23 A. Yes. 24 24 Q. And your daughteris? 25 25 A. Sirsa. Page354 Page356 1 M UN I R S E E N, I Q. How do you spellthat? 2 Calledas a witness, having been first dulysworn by 2 A. S-I-R-S-A. 3 aNotary PublicoftheStateof New York, was 3 Q. Now, which friend was present? 4 examined and testified as follows: 4 A. It's a family friend. 5 EXAMINATION BY 5 Q. What is yourfriend'sname, please? 6 MR. CASIMIR: 6 A. Abdalla. 7 Q. Good Mr. afternoon, Seen. Let me know if I am 7 Q. Abdalla? 8 pronouncingyour Is it Seen? name correctly. 8 A. Yes, Odeh. 9 A. Yes, sir. 9 Q. How do you spellthe lastname? 10 Q. Okay, Good afternoon,Mr. Seen. 10 A. O-D-E-H. 11 A. Good afternoon. 11 Q. Okay. Now, withreference to yourmarriage to 12 Q. My name is GaryCasimir,and we're going to do a 12 Ms. Basha, was therean engagement priorto the 13 very limited short, discoverydeposition.It's going to 13 marriage? 14 marriage focus on your and what has been filed as an 14 A. No. 15 economic in this case, okay? report 15 Q. Priortothe marriage toMs. Basha, didyou live 16 A. Okay. 16 together? 17 Q. The first thingI want sir, are you to ask you, 17 A. No. 18 married? currently 18 Q. When did you first meet Ms. Basha? 19 A. Yes. 19 A. Oh, a year-and-a-half ago. 20 Q. During yourprior do you recall deposition, if 20 Q. Priorto your marriage toMs. Basha, was she 2I you were marriedthen? 21 aware of your current conditicñ? 22 A. No. 22 A. Justbefore we got married, yes. Not when we 23 Q. When were youmarried? 23 met. 24 A. October 20th. 24 Q. Was Ms. Basha ever previouslymarried? 25 Q. Is that October 20, 2018? 25 A. Oh, yeah. 3 (Pages 353 - 356) Priority-One Court Services Inc. - A Veritext Reporting Company 718-983-1234 FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 Page 357 Page359 I Q. Who was she previously marriedto? 1 Ms. Basha? 2 A. I have no idea. 2 A. November 2018. 3 Q. Do you know when Ms. Basha obtainedher divorce 3 Q. You indicated that.So was Ms. Basha living here 4 frorn her last marriage? 4 in November starting 2018? 5 A. Yes. 5 A. Yes. 6 Q. When was that? 6 Q. And at that time were you in a different living 7 A. June 5th, 2018. 7 location yourself? 8 Q. Where did Ms. husband Basha and her previous 8 A. Yes. 9 live? 9 Q. Where wereyou living? 10 A. Haledon. 10 A. 1412 Summer HillRoad, Wayne,New Jersey. 11 Q. Here? 11 Q. Previousto yourmarriageto Basha, were you 12 A. Yes. 12 married? 13 MR. CASIMIR: Let the record that we reflect 13 A. No. 14 are currently at, I think, 40 Lupton -- 14 Q. I'm sorry.Letme rephrase that question. How 15 THE WITNESS: No, no. 15 many timeshave you been marriedall together? 16 MR. CASIMIR: No? 16 MR. BLOUIN: That was coveredin the first 17 THE WITNESS: No. They didn'tlivehere. 17 deposition. 18 They livedin this town. 18 MR. CASIMIR: I understand to It's going 19 MR. CASIMIR: Oh, in this complex? 19 lead to a question that's related to this inquiry. 20 THE WITNESS: In this town. 20 Q. How many times were youmarriedbeforeall 21 MR. CASIMIR: In this town? 21 together? 22 THE WITNESS: Not the complex,not this 22 A. Three times. 23 apartment. 23 Q. Three timesall together? 24 MR. CASIMIR: But in Haldale? 24 A. Yes. 25 THE WITNESS: Haledon. I'msorry,I cannot 25 Q. And your last wife, based on your previous Page358 Page360 1 speak too loud,okay. 1 deposition,was Inam Idris? 2 MR. CASIMIR: No problem. Ifat anytime 2 A. Yes. 3 you need to take a break,we can take a break.I'n 3 Q. Did you obtain a divorcefrom Inam Idris? 4 justtryingtomove as quickly as possible,okay? 4 A. Yes. 5 THE WITNESS: Okay. 5 Q. Prior tothat,what yeardid you obtain the 6 6 divorce from Ms. Idris? 7 CONTINUED EXAMINATION BY 7 A. No idea. 8 MR. CASIMIR: 8 Q. Okay. Priortothat,were you married to Hana 9 Q. Allright.Now, I understand thatyou were 9 Mamkegh? 10 married at theIslamicCenter inUnion County? 10 A. Mamkegh. I1 A. Yes. 11 Q. Can you spellthat lastname, please? 12 Q. Did you alsogo to Hall -- 12 A. It's hard for me also. City 13 A. No. 13 Q. It's hard for you also. 14 Q. -- toobtain a marriage license? 14 A. Yes. 15 A. No. 15 Q. Go ahead. 16 Q. Do you and Basha currentlylivetogetherinthir 16 A. M-A-M-K-E-G-H. 17 home? 17 MR. CASIMIR: Can the courtreporter pleas¤ 18 A. Yes. 18 read back the spelling. 19 Q. Was this Basha'shome -- 19 (Whereupon the referred-to answer was read 20 A. No. 20 back by the court reporter.) 21 Q. --prior toyour marriage? 21 Q. Is that correct,what the courtreporterjust 22 A. No. 22 read back? 23 Q. Whose home was thisprior toyour marriage? 23 A. Yes. 24 A. I have no idea.We justrentit. 24 Q. Can you pleasespell herfirstname? 25 Q. When did you first startrenting thishome with 25 A. H-A-N-A. 4 (Pages 357 - 360) Priority-One Court Services Inc. - A Veritext Reporting Company 718-983-1234 FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 Page361 Page363 1 Q. Just one "N"? I minutes,and I think that youwillsee whereit's 2 A. Yes. 2 going. 3 Q. Is this her maiden name? 3 MR. BLOUIN: No, I don't want to wait. I 4 A. Yes. 4 don'twant youto -- 5 Q. Did she ever take your name on, Seen? 5 MR. CASIMIR: Well,I'm goingto ask the 6 A. No. 6 and you question, can direct him not to answer it. 7 Q. Where were you two married? 7 That'show it works.Okay? I understand what you' 8 A. Jordan. 8 e saying,but -- 9 Q. Jordan? 9 MR. BLOUIN: Or maybe we willjustshut the 10 A. Yes. 10 depositiondown and do the video, because we had an II Q. When you came here in '67 or '68, did she come 11 agreement are now that you breaking. 12 here withyou -- 12 MR. CASIMIR: Ifyou feel sensitive about 13 A. No. 13 whateveryou thinkI'm breakingbecause youare not 14 Q. -- or did she come here after? 14 seeingthebiggerpicture,that's toyou, up 15 A. No, she came here after. 15 counselor. 16 Q. What year didMs. Mamkegh -- I apologize that I 16 MR. BLOUIN: What is the bigger pictue? 17 can't say her name. What year didHana come? 17 Why don't you tellme. 18 A, Late '70s. 18 MR. CASIMIR: Let me ask the questions and 19 Q. '70s? 19 you'll see. 20 A. Late '70s. 20 MR. BLOUIN: I wantan offer of proofor the 21 Q. You have two childrenwithHana, forshort, 21 deposition's done. 22 correct? 22 MR. CASIMIR: I'm just goingto ask him 23 A. Yes. 23 simplequestionsabout where theylived and when 24 Q. When you weremarried to Hana,where did youlive 24 theygot divorced.I'm allowed totally toask 25 withher? 25 those questions. Page362 Page364 1 A. United States and Jordan. Backand forthbetween 1 MR. BLOUIN: No, you'renot, because you 2 U.S.and Jordan. 2 have broken basically another agreementwithme. 3 Q. Did you ever live in New Jersey with her? 3 MR. CASIMIR: I don't have any other 4 A. Yes. 4 agreement withyou. Thisis the only timewe've 5 Q. Where did you with live her in NewJersey? 5 talkedaboutit. 6 A. I don't know. We kept moving from one apâitmcñt 6 MR. BLOUIN: It's in the e-mails. in writing 7 to the another, so... 7 MR. CASIMIR: I intend to ask about his 8 Q, Can you justgiveme the general towns, locations 8 marriages, to -- and I intend 9 or counties? 9 MR. BLOUIN: No, not about his marriages, 10 A. Okay. Passaic Countymostly. 10 about his new marriage. Okay, deposition over. 1I Q. Passaic? 11 Let's take the video. 12 A. Yes. 12 MR. CASIMIR: Dan, calmdown. 13 Q. You had two childrenwithher in the United 13 MR. BLOUIN: Let's take the video. 14 States? 14 MR. CASIMIR: Calm down. 15 A. Yes. 15 MR. BLOUIN: Ifyou have a problem, you can I6 MR. BLOUIN: Okay. This was all covered in 16 callthe special master. We're doingthe video in 17 the first deposition.I'mnot letting him answer 17 the meantime. 18 any more questions about anythingthat was outside 18 MR. CASIMIR: I have 30 minutes. Do you 19 of the topics that we agreed upon to go forward in 19 want me to do the 30 minutes? 20 this deposition. This all covered is literally in 20 MR. BLOUIN: No, you don't get a 30-minute 21 the first deposition.You said that we're goingto 21 depositionabout whateva you see fit. 22 talkabout his marriage and economicsafter 22 MR. CASIMIR: Dan, you'reright now breaking 23 marriage,his new marriage and nothingelse.This 23 down over one question. The answer is -- 24 is not going anywhere that can be articulated. 24 MR. BLOUIN: No, you -- asked 20 question 25 MR. CASIMIR: I'malmost done in two 25 MR. CASIMIR: -- youdon'tanswer the 5 (Pages 361 - 364) Priority-One Court Services Inc. - A Veritext Reporting Company 718-983-1234 FILED: NEW YORK COUNTY CLERK 08/27/2019 03:08 PM INDEX NO. 190225/2018 NYSCEF DOC. NO. 250 RECEIVED NYSCEF: 08/27/2019 Page365 Page367 1 questionand then we moveon to somethingelse. I was previouslycovered. I have the depositicñ 2 You don'thave a nuclear incidentbecause youdon't 2 transcript. 3 likea question. You say, no, I'm not goingto let 3 Q. Did you get a divorce fromHana in New Jersey? 4 him answer andmove on toanotherquestion. 4 MR. BLOUIN: You don'tneed to answer that 5 MR. BLOUIN: I'mnot -- he has been 5 question. 6 questionsfor the past five minutes -- 6 Q. Do you recallthe county in whichthe divorce answering 7 I've been watching -- the clock 7 was filed? 8 MR. CASIMIR: Right. 8 MR. BLOUIN: Allof this could have been 9 MR. BLOUIN: -- aboutstuff outsideof what 9 coveredin the Defendant's deposition. discovery 10 you agreed to ask questions about. 10 Objection. 11 MR. CASIMIR: I understand you thinkit's 1I You don'tneed to answerthis question. 12 but you're outside, making a claim for spousal 12 MR. CASIMIR: Counsel is blocking questions 13 support.There are issues there. I don't have to 13 relevantto his current claimofa new marriage 14 teach youhow to do this. I knowyou know. I'm 14 I'm and, therefore, going to seek a motion to bring 15 goingto coverthis area. It maylead to nothing. 15 back the witness and ask any and all relevant 16 It is a discovery deposition.I am entitled to ask 16 questionsto the new claim concerñinga more recent 17 these questions. I understand you feel -- 17 marriage. 18 MR. BLOUIN: About marriages? his previous 18 So let's just move on to the ecenemic report 19 MR. CASIMIR: Yes. They to are important 19 at this time. 20 the -- yes. They coverissues, Dan. 20 Q. Mr. familiar Seen, are you at all with an 21 MR. BLOUIN: No, theydo not. 21 economic reportthat your attorneyhas filed on your 22 MR. CASIMIR: You can ask -- 22 behalf? 23 MR. BLOUIN: No, that's not what we agreed 23 A. Yes. 24 upon. 24 MR. BLOUIN: Have you seen an economic 25 MR. CASIMIR: You can justblockthe 25 report? Page366 Page368 1 questionand we willmove on to the next one. It's 1 THE WITNESS: No. 2 okay. perfectly I will make a motionto bring