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FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019
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DEFENDANTS'
EXHIBIT C
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2 ; SUPREME COURT OF THE STATE OF NEW YORK
i
3 COUNTY OF NASSAU
4 INDEX NO. O08291-2014
5 -----------------------------------------x
6 JAMES MORAN,
7 Plaintiff,
8 -against-
9 GRAND SLAM LLC and "JOHN DOES"
VENTURES,
10 and/or JANE DOES #1-25 inclusive, the last
11 ten names being fictitious and unknown to
12 p1aintiff,
13 Defendants.
14 -----------------------------------------x
15 November 6, 2019
10:09 a.m.
16
17 Deposition of GLENN REINER, taken
18 by the Plaintiff, pursuant to Subpoena,
19 held at the offices of Veritext Reporting,
20 Inc., 330 O1d Country Road, Mineola, New
21 York, before R. Bobbie Levy, a Certified
22 Shorthand Reporter and Notary Public of the
23 State of New York.
2 4
25
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2 A P P E A R A N C E S :
3
4
5 JAMES MORAN, ESQ.
6 PLAINTIFF PRO SE
7 28 Carrie Avenue
8 Bethpage, New York 11714
9
10
11
12 SIEGEL & REINER, LLP
13 Attorneys for Defendants
14 130 East 59th Street
15 New York, New York 10022
16
17 BY: RICHARD H. DEL VALLE, ESQ.
18
19
20
21
22
23
24
25
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2 S T I P U L A T I O N S
3 IT IS HEREBY STIPULATED AND
4 AGREED by and between counsel for the
5 respective parties hereto, that:
6 All rights provided by the
7 C.P.L.R. and Part 221 of the Uniform Rules
8 for the Conduct of Depositions, including
9 the right to object to any question,
10 except as to the form, or to move to
11 strike any testimony at this examination,
12 are reserved; and, in addition, the
13 failure to object to any question or to
14 move to strike any testimony at this
15 examination shall not be a bar or waiver
16 to make such motion at, and is reserved
17 for, the trial of this action.
18 This examination may be sworn to
19 by the witness being examined before a
20 I Notary Public other than the Notary Public
21 before whom the examination was begun, but
22 the failure to do so, or to return the
23 original of this examination to counsel,
24 I shall not be deemed a waiver of the rights
25 provided by Rule 3116 of the C.P.L.R. and
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1
2 shall be controlled thereby.
3 The filing of the original of
4 this examination is waived.
5 IT IS FURTHER STIPULATED , a copy
!
6 of this examination shall be furnished to
7 the attorney for the witness being
8 examined without charge.
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
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1 G. Reiner
2 G L E N N R E I N E R,
3 called as a witness, having been first
4 duly sworn by the Notary Public, was
5 examined and testified as follows:
6 TAKEN BY
7 THE COURT REPORTER
8 Q Please state your name for the
9 record.
10 A Glenn Reiner.
111 Q What is your current address?
12! A (Business) 130 East 59th Street,
13 New York New York 10022.
14 EXAMINATION BY
15 MR. MORAN:
16 Q Good morning, Mr. Reiner. As
17 you know, my name is James Moran. I'll be
18 asking you some questions today. If you
19 don't understand my questions today I'll
20 ask that you please let me know and I'll
21 rephrase it for you. Do you understand
22 that?
23 A Yes .
24 Q If you need a break just let me
25 know and we will do our best to
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1 G. Reiner
2 accommodate you, as long as there's not a
3 question pending.
4 Are you currently under the
5 influence of any medication, drug or
6 alcohol that would impair or hinder your
7 ability to answer questions in this case
8 today?
9 A No.
10 Q Are you currently employedo
11 A Yes.
12 Q Where do you work?
13 A Siegel & Reiner, LLP.
14 Q Is that your law firm?
15 A I'm a partner in the law firm,
16 yes.
17 Q Did there come a time that you
18 were familiar with Grand Slam Ventures,
19 LLC?
20 A Yes.
21 Q Can you describe how you became
22 familiar with that entity?
23 A I began representing them in
24 around 2010, no, probably 2008. When they
25 were lending money to an entity known as
VeritextLegalSolutions
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.,.....-.. COUNTY
,..- ,,......CLERK
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2 219, LLC and to a guarantor James Moran.
3 Q Did you set up the entity Grand
4 Slam Ventures, did you file the articles
5 of incorporation?
6 A I don't believe so.
7 Q Did you have any other
8 involvement with Grand Slam Ventures other
9 than acting as their attorney?
10 A No.
11 Q Do you ever invest any money in
12 Grand Slam Ventures?
13 | A No.
14 Q Did you ever loan any money to
15 Grand Slam Ventures?
16 A No.
17 Q Did you ever pay any bills or
18 expenses on behalf of Grand Slam Ventures?
19 A Not that I remember.
20 Q I wou.1d ask the same questions
21 with regards to your law firm. Did your
22 law firm ever pay any bills or expenses
23 with regards to Grand Slam Ventures9
24 A We may have laid out money but
25 we were probably reimbursed but I don't
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2 remember off the top of my head.
3 Q Did your law firm i.nvest any
4 money9
5 A No.
6 Q Loan any money?
7 A No.
8 Q So the only thing 1s you might
9 have paid some bills or expenses on behalf
10 of them?
11 A We often will pay client
12 disbursements and get reimbursed
13 afterwards.
14 Q Would what would those
15 disbursements be for court costs?
16 A Court costs, filing fees,
17 formation of documents . Court services.
18 Q Anything outside that area?
19 A No, not typically.
20 Q Would you have paid any taxes or
21 insurance?
22 A No.
23 Q Do you know who the investors of
24 Grand Slam Ventures were?
25 A No, I don't. Not off the top of
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1 G. Reiner
2 my head anyway.
3 Q Did you set up any agreements
4 with the investors?
5 A I did not.
6 Q Do you know if Grand Slam
7 Ventures had any employees?
8 A I do not.
9 Q So other than acting as the
10 attorney for Grand Slam Ventures you had
11 no involvement whatsoever9
12 A To the best of my recollection.
13 Q Is there something that could
14 refresh your recollection as to whether
15 you had an involvement with it?
16 A I don't believe so.
17 MR. MORAN: I would like to mark
18 that as Plaintiff's 1.
19 (Whereupon, assignment of
20 contracts was marked as Plaintiff's
21 Exhibit 1 for identification, as of
22 this date.)
23 Q I"m going to show you what's
24 been marked as Plaintiff's Exhibit 1. Can
25 you take a look at that document and let
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1 G. Reiner
2 me know when you are finished.
3 (Handing)
4 (Pause)
5 A Uh-huh.
6 Q Can you turn to page 7 of that
7 document. It's marked at the bottom.
8 A Yes.
9 Q Is that your signature?
10 A Yes.
11 Q Did you sign that as manager of
12 Grand Slam Ventures?
13 A I did.
14 Q Why would you have done that?
15 A Well, from authoriza'tions from
16 / the members of Grand Slam I had often
17 si gned documents as manager or as an
18 assistant secretary on their behalf, on
19 various, on for various clients and
20 various entities.
21 Q Were you a manager of Grand Slam
22 Ventures?
23 A That day I was.
24 Q And how do you become a manager?
25 A By members consent typically.
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2 Q What members were there?
3 A I don't remember off the top of
4 my head.
5 Q So who would you have gotten
6 consent to sign that then?
7 A Probably the managing member at
8 the time. John Steinberg.
9 Q But you signed it as a manager?
10 A That is correct.
11 Q And Mr. Steinberg gave you
12 permission to do at that?
13 A Authorized me to do so, yes.
14 Q Do you know Mr. Steinberg has
15 testified that had he didn't give you any
16 authorization to do that?
17 A I do not know that.
18 Q Okay. Are you familiar with an
19 entity known as JG Real Estate Ventures?
20| A Yes.
21 Q Are you a member of that entity?
22 MR. DEL VALLE: Objection. You
23 can answer .
24 A Yes.
25 Q When did you become a member of
(
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2 that entity?
3 MR. DEL VALLE: Objection. I'm
4 going to direct the witness not to
5 answer that question.
6 MR. MORAN: I guess we are going
7 for a ruling then.
8 MR. DEL VALLE: Do you want to
9 call her up first?
10 MR. MORAN: We will go over
11 there. I don't know if it's going to
12 be her or who it's going to be.
13 MR. DEL VALLE: JG is not a
14 party to this action.
15 MR. MORAN: Off the record.
16 (Discussion off the record)
17 MR. MORAN: We can be on the
18 record. It doesn't matter that they
19 are not a party to the action.
20 The objective of this deposition
21 is to determine assets of Grand Slam
22 Ventures. Grand Slam Ventures owned
23 the building that was transferred to
24 JG. I have the right to inquire of
25 that transfer.
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2 MR. DEL VALLE: It's irrelevant.
3 MR. MORAN: It's irrelevant?
4. MR. DEL VALLE: It's irrelevant.
5 MR. MORAN: We're going to go
6 for a ruling then.
7 (Discussion off the record)
8 MR. DEL VALLE: I have
9 previously directed the witness not to
10 answer the question of when he became
11 a member of the JG LLC. We will mark
12 it for a ruling.
13 Mr. Reiner is willing to
i
14 continue answering questions regarding
15 JG until we find that it gets into an
16 area that is either irrelevant or
17 prejudicial to my client's interest.
18 Q Are you answering the question
19 as to when you became a member?
20 A Yes, I will answer the question.
21 MR. DEL VALLE: Then strike the
22 last part then.
23 MR. MORAN: Okay.
24 Q When did you become a member of
25 JG Real Estate Ventures?
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2 THE WITNESS: Off the record one
3 second.
4 (Discussion off the record)
5 A Somewhere in the early 2010's.
6 Q Did there come a time JG Real
7 Estate Ventures became the owner of a
8 property known as 219 West Hempstead
9 Turnpike?
10 A Yes.
11 Q When was that?
12 A Somewhere early in the 2010's.
13 Q How did they become an owner of
14 that property?
15 A By assignment of bid from on the
16 foreclosure sale of 219 LLC.
17 Q And what was the assignment of
18 bid for? What consideration was given for
19 it, I should say?
20 A There was substantial
.
21 obligations owed on the property that JG
22 had agreed to assume.
23 Q What obligations were those?
24 A Mostly real estate taxes.
25 Q And how much were those real
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1 G. Reiner
2 estate taxes?
3 A Approximately over 100,
4 approximately 100 and something thousand
5 dollars.
6 Q So when JG Real Estate Ventures
7 became the owner of the property it paid
8 the real estate taxes?
9 A Sometime thereafter, yes.
10 Q Was there any other
11 consideration given?
12 A Not that I can recall at this
13 moment.
14 MR. MORAN: We can mark this as
15 Plaintiff's 2.
16 (Whereupon, assignment of bid
17 document was marked
Preview
FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 82 RECEIVED NYSCEF: 08/25/2022 DEFENDANTS' EXHIBIT C .....-. FILED: ....--..- NASSAU --..... COUNTY --...- CLERK --,..-.,..--- 08/25/2022 --.... 05:33 PM...., INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 53 82 RECEIVEDNYSCEF: RECEIVED NYSCEF:06/24/2022 08/25/2022 Page 1 1 2 ; SUPREME COURT OF THE STATE OF NEW YORK i 3 COUNTY OF NASSAU 4 INDEX NO. O08291-2014 5 -----------------------------------------x 6 JAMES MORAN, 7 Plaintiff, 8 -against- 9 GRAND SLAM LLC and "JOHN DOES" VENTURES, 10 and/or JANE DOES #1-25 inclusive, the last 11 ten names being fictitious and unknown to 12 p1aintiff, 13 Defendants. 14 -----------------------------------------x 15 November 6, 2019 10:09 a.m. 16 17 Deposition of GLENN REINER, taken 18 by the Plaintiff, pursuant to Subpoena, 19 held at the offices of Veritext Reporting, 20 Inc., 330 O1d Country Road, Mineola, New 21 York, before R. Bobbie Levy, a Certified 22 Shorthand Reporter and Notary Public of the 23 State of New York. 2 4 25 VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVEDNYSCEF: RECEIVED NYSCEF:06/24/2022 08/25/2022 Page 2 1 2 A P P E A R A N C E S : 3 4 5 JAMES MORAN, ESQ. 6 PLAINTIFF PRO SE 7 28 Carrie Avenue 8 Bethpage, New York 11714 9 10 11 12 SIEGEL & REINER, LLP 13 Attorneys for Defendants 14 130 East 59th Street 15 New York, New York 10022 16 17 BY: RICHARD H. DEL VALLE, ESQ. 18 19 20 21 22 23 24 25 VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: .....--- . NASSAU ....--.. COUNTY CLERK ....--- 08/25/2022 - ...-. 05:33 ... . PM ...-. INDEX NO. 001052/2019 -, ...., NYSCEF NYSCEF DOC. DOC. NO. NO. 53 82 RECEIVED NYSCEF:06/24/2022 RECEIVEDNYSCEF: 08/25/2022 Page 3 1 2 S T I P U L A T I O N S 3 IT IS HEREBY STIPULATED AND 4 AGREED by and between counsel for the 5 respective parties hereto, that: 6 All rights provided by the 7 C.P.L.R. and Part 221 of the Uniform Rules 8 for the Conduct of Depositions, including 9 the right to object to any question, 10 except as to the form, or to move to 11 strike any testimony at this examination, 12 are reserved; and, in addition, the 13 failure to object to any question or to 14 move to strike any testimony at this 15 examination shall not be a bar or waiver 16 to make such motion at, and is reserved 17 for, the trial of this action. 18 This examination may be sworn to 19 by the witness being examined before a 20 I Notary Public other than the Notary Public 21 before whom the examination was begun, but 22 the failure to do so, or to return the 23 original of this examination to counsel, 24 I shall not be deemed a waiver of the rights 25 provided by Rule 3116 of the C.P.L.R. and VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 NYSCEF:06/24/2022 RECEIVEDNYSCEF: RECEIVED 08/25/2022 Page 4 1 2 shall be controlled thereby. 3 The filing of the original of 4 this examination is waived. 5 IT IS FURTHER STIPULATED , a copy ! 6 of this examination shall be furnished to 7 the attorney for the witness being 8 examined without charge. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: .. ...--. NASSAU ....--..- COUNTY ---., CLERK 08/25/2022 .---- 05:33 --....-. PM.., INDEX NO. 001052/2019 ., NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVED NYSCEF:06/24/2022 RECEIVEDNYSCEF: 08/25/2022 ...... .------ .. . . .. - . _ .-.... ... .. . --- ...-__.---.. _ _..... .____ .- Page 5 1 G. Reiner 2 G L E N N R E I N E R, 3 called as a witness, having been first 4 duly sworn by the Notary Public, was 5 examined and testified as follows: 6 TAKEN BY 7 THE COURT REPORTER 8 Q Please state your name for the 9 record. 10 A Glenn Reiner. 111 Q What is your current address? 12! A (Business) 130 East 59th Street, 13 New York New York 10022. 14 EXAMINATION BY 15 MR. MORAN: 16 Q Good morning, Mr. Reiner. As 17 you know, my name is James Moran. I'll be 18 asking you some questions today. If you 19 don't understand my questions today I'll 20 ask that you please let me know and I'll 21 rephrase it for you. Do you understand 22 that? 23 A Yes . 24 Q If you need a break just let me 25 know and we will do our best to VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: .......--. NASSAU ....--..- COUNTY ---.... CLERK -...-.- 08/25/2022 --,... 05:33 .... PM ., INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVEDNYSCEF: RECEIVED NYSCEF:06/24/2022 08/25/2022 Page 6 1 G. Reiner 2 accommodate you, as long as there's not a 3 question pending. 4 Are you currently under the 5 influence of any medication, drug or 6 alcohol that would impair or hinder your 7 ability to answer questions in this case 8 today? 9 A No. 10 Q Are you currently employedo 11 A Yes. 12 Q Where do you work? 13 A Siegel & Reiner, LLP. 14 Q Is that your law firm? 15 A I'm a partner in the law firm, 16 yes. 17 Q Did there come a time that you 18 were familiar with Grand Slam Ventures, 19 LLC? 20 A Yes. 21 Q Can you describe how you became 22 familiar with that entity? 23 A I began representing them in 24 around 2010, no, probably 2008. When they 25 were lending money to an entity known as VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: ........--. NASSAU .,.....-.. COUNTY ,..- ,,......CLERK ...--- 08/25/2022 --,.. . .---... 05:33 --....-- PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVEDNYSCEF: RECEIVED NYSCEF:06/24/2022 08/25/2022 Page 7 1 G. Reiner 2 219, LLC and to a guarantor James Moran. 3 Q Did you set up the entity Grand 4 Slam Ventures, did you file the articles 5 of incorporation? 6 A I don't believe so. 7 Q Did you have any other 8 involvement with Grand Slam Ventures other 9 than acting as their attorney? 10 A No. 11 Q Do you ever invest any money in 12 Grand Slam Ventures? 13 | A No. 14 Q Did you ever loan any money to 15 Grand Slam Ventures? 16 A No. 17 Q Did you ever pay any bills or 18 expenses on behalf of Grand Slam Ventures? 19 A Not that I remember. 20 Q I wou.1d ask the same questions 21 with regards to your law firm. Did your 22 law firm ever pay any bills or expenses 23 with regards to Grand Slam Ventures9 24 A We may have laid out money but 25 we were probably reimbursed but I don't VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 NYSCEF:06/24/2022 RECEIVEDNYSCEF: RECEIVED 08/25/2022 Page 8 1 G. Reiner 2 remember off the top of my head. 3 Q Did your law firm i.nvest any 4 money9 5 A No. 6 Q Loan any money? 7 A No. 8 Q So the only thing 1s you might 9 have paid some bills or expenses on behalf 10 of them? 11 A We often will pay client 12 disbursements and get reimbursed 13 afterwards. 14 Q Would what would those 15 disbursements be for court costs? 16 A Court costs, filing fees, 17 formation of documents . Court services. 18 Q Anything outside that area? 19 A No, not typically. 20 Q Would you have paid any taxes or 21 insurance? 22 A No. 23 Q Do you know who the investors of 24 Grand Slam Ventures were? 25 A No, I don't. Not off the top of VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 53 82 RECEIVED NYSCEF:06/24/2022 RECEIVEDNYSCEF: 08/25/2022 Page 9 1 G. Reiner 2 my head anyway. 3 Q Did you set up any agreements 4 with the investors? 5 A I did not. 6 Q Do you know if Grand Slam 7 Ventures had any employees? 8 A I do not. 9 Q So other than acting as the 10 attorney for Grand Slam Ventures you had 11 no involvement whatsoever9 12 A To the best of my recollection. 13 Q Is there something that could 14 refresh your recollection as to whether 15 you had an involvement with it? 16 A I don't believe so. 17 MR. MORAN: I would like to mark 18 that as Plaintiff's 1. 19 (Whereupon, assignment of 20 contracts was marked as Plaintiff's 21 Exhibit 1 for identification, as of 22 this date.) 23 Q I"m going to show you what's 24 been marked as Plaintiff's Exhibit 1. Can 25 you take a look at that document and let VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVED RECEIVEDNYSCEF: NYSCEF:06/24/2022 08/25/2022 Page 10 1 G. Reiner 2 me know when you are finished. 3 (Handing) 4 (Pause) 5 A Uh-huh. 6 Q Can you turn to page 7 of that 7 document. It's marked at the bottom. 8 A Yes. 9 Q Is that your signature? 10 A Yes. 11 Q Did you sign that as manager of 12 Grand Slam Ventures? 13 A I did. 14 Q Why would you have done that? 15 A Well, from authoriza'tions from 16 / the members of Grand Slam I had often 17 si gned documents as manager or as an 18 assistant secretary on their behalf, on 19 various, on for various clients and 20 various entities. 21 Q Were you a manager of Grand Slam 22 Ventures? 23 A That day I was. 24 Q And how do you become a manager? 25 A By members consent typically. VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVED NYSCEF:06/24/2022 RECEIVEDNYSCEF: 08/25/2022 Page 11 1 G. Reiner 2 Q What members were there? 3 A I don't remember off the top of 4 my head. 5 Q So who would you have gotten 6 consent to sign that then? 7 A Probably the managing member at 8 the time. John Steinberg. 9 Q But you signed it as a manager? 10 A That is correct. 11 Q And Mr. Steinberg gave you 12 permission to do at that? 13 A Authorized me to do so, yes. 14 Q Do you know Mr. Steinberg has 15 testified that had he didn't give you any 16 authorization to do that? 17 A I do not know that. 18 Q Okay. Are you familiar with an 19 entity known as JG Real Estate Ventures? 20| A Yes. 21 Q Are you a member of that entity? 22 MR. DEL VALLE: Objection. You 23 can answer . 24 A Yes. 25 Q When did you become a member of ( VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVEDNYSCEF: RECEIVED NYSCEF:06/24/2022 08/25/2022 Page 12 1 G. Reiner 2 that entity? 3 MR. DEL VALLE: Objection. I'm 4 going to direct the witness not to 5 answer that question. 6 MR. MORAN: I guess we are going 7 for a ruling then. 8 MR. DEL VALLE: Do you want to 9 call her up first? 10 MR. MORAN: We will go over 11 there. I don't know if it's going to 12 be her or who it's going to be. 13 MR. DEL VALLE: JG is not a 14 party to this action. 15 MR. MORAN: Off the record. 16 (Discussion off the record) 17 MR. MORAN: We can be on the 18 record. It doesn't matter that they 19 are not a party to the action. 20 The objective of this deposition 21 is to determine assets of Grand Slam 22 Ventures. Grand Slam Ventures owned 23 the building that was transferred to 24 JG. I have the right to inquire of 25 that transfer. VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVED NYSCEF:06/24/2022 RECEIVEDNYSCEF: 08/25/2022 Page 13 1 G. Reiner 2 MR. DEL VALLE: It's irrelevant. 3 MR. MORAN: It's irrelevant? 4. MR. DEL VALLE: It's irrelevant. 5 MR. MORAN: We're going to go 6 for a ruling then. 7 (Discussion off the record) 8 MR. DEL VALLE: I have 9 previously directed the witness not to 10 answer the question of when he became 11 a member of the JG LLC. We will mark 12 it for a ruling. 13 Mr. Reiner is willing to i 14 continue answering questions regarding 15 JG until we find that it gets into an 16 area that is either irrelevant or 17 prejudicial to my client's interest. 18 Q Are you answering the question 19 as to when you became a member? 20 A Yes, I will answer the question. 21 MR. DEL VALLE: Then strike the 22 last part then. 23 MR. MORAN: Okay. 24 Q When did you become a member of 25 JG Real Estate Ventures? VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF NYSCEF DOC. DOC. NO. NO. 8253 RECEIVED NYSCEF:06/24/2022 RECEIVEDNYSCEF: 08/25/2022 Page 14 1 G. Reiner 2 THE WITNESS: Off the record one 3 second. 4 (Discussion off the record) 5 A Somewhere in the early 2010's. 6 Q Did there come a time JG Real 7 Estate Ventures became the owner of a 8 property known as 219 West Hempstead 9 Turnpike? 10 A Yes. 11 Q When was that? 12 A Somewhere early in the 2010's. 13 Q How did they become an owner of 14 that property? 15 A By assignment of bid from on the 16 foreclosure sale of 219 LLC. 17 Q And what was the assignment of 18 bid for? What consideration was given for 19 it, I should say? 20 A There was substantial . 21 obligations owed on the property that JG 22 had agreed to assume. 23 Q What obligations were those? 24 A Mostly real estate taxes. 25 Q And how much were those real VeritextLegalSolutions 212-267-6868 www.veritext.com 516-608-2400 FILED: NASSAU COUNTY CLERK 08/25/2022 05:33 PM INDEX NO. 001052/2019 NYSCEF DOC. NO. 53 RECEIVED NYSCEF DOC. NO. 82 RECEIVEDNYSCEF: NYSCEF:06/24/2022 08/25/2022 Page 15 1 G. Reiner 2 estate taxes? 3 A Approximately over 100, 4 approximately 100 and something thousand 5 dollars. 6 Q So when JG Real Estate Ventures 7 became the owner of the property it paid 8 the real estate taxes? 9 A Sometime thereafter, yes. 10 Q Was there any other 11 consideration given? 12 A Not that I can recall at this 13 moment. 14 MR. MORAN: We can mark this as 15 Plaintiff's 2. 16 (Whereupon, assignment of bid 17 document was marked