Preview
FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021
Case 9:21-cv-80160-DMM Document 47-2 Entered on FLSD Docket 08/06/2021 Page 1 of 700
NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 01/05/2022
EXHIBIT
FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021
Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on
Docket 08/06/2021 Page2of700
NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. ° 9:21-cv-80160
PATRICK GORHAM and
NORTHWEST PACIFIC PROPERTY
MANAGEMENT, LLC,
Plaintiffs,
vs.
MICHELLE KAUFMAN, CLAUDIA MATHIS, and
EXPEDIA FINANCIAL CONSULTANTS, INC.,
d/b/a REGROUP PARTNERS, INC.,
Defendants.
O O O
- CORRECTED TRANSCRIPT -
DEPOSITION OF CLAUDIA MATHIS
APPEARING REMOTELY FROM
PALM BEACH COUNTY, FLORIDA
Pages 1 through 298
Tuesday, June 22, 2021
9:01 a.m. - 3:55 p.m.
Stenographically Reported By:
Amy Lyon
APPEARING REMOTELY FROM BROWARD COUNTY, FLORIDA
U.S. Legal Support | www.uslegalsupport.com
FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021
Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD
on Docket 08/06/2021 Page 3 of 700
NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
1 REMOTE APPEARANCES:
2 ON BEHALF OF THE PLAINTIFFS:
3 Greenspoon Marder, P.A.
200 East Broward Boulevard
4 Suite 1800
Fort Lauderdale, Florida 33301
5 954-491-1120
Aaron.williams@gmlaw.com
6 BY: AARON T. WILLIAMS, ESQUIRE
7
ON BEHALF OF THE DEFENDANTS:
8
Rosenthal Law Group
9 2115 North Commerce Parkway
Weston, Florida 33326
10 954-384-9200
Alex@rosenthalcounsel.com
11 Amanda@rosenthalcounsel. com
BY: AMANDA JONES, ESQUIRE
12
and
13
ALEX P. ROSENTHAL, ESQUIRE
14
15 ALSO PRESENT: ° MICHELLE KAUFMAN -
Telephonically
PATRICK GORHAM
16
17
18
19
20
21
22
23
24
25
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NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
1 INDEX TO PROCEEDINGS
2 Remote Deposition of CLAUDIA MATHIS PAGE
3 Direct Examination by Ms. Jones 6
Certificate of Oath 294
4 Certificate of Reporter 295
Witness Notification Letter 296
5 Errata Sheet 297
Certificate on Corrections 298
6
INDEX OF EXHIBITS
7
PLAINTIFFS' EXHIBITS PAGE
8 NO. DESCRIPTION
9 1 - Fictitious Name 17
Filing
2 - BizFund Contract 37
10 3 - BizFund Settlement 40
4 - Capital Contract 45
Broadway
11 5 - Capital Settlement 47
Broadway
6 - Website Screenshot 71
12 7 - Email 121
8 - Email 137
13 9 - Email 148
10 - Contract 152
14 11 - BizFund Lawsuit 170
12 - Cash Statement 191
Petty
15 13 - Bates Stamps 402-453 196
14 - Complaint 225
16 15 - Payoff Spreadsheet 241
16 - Email 2020 244
Aug 4,
17 17 - Email 2020 256
Aug 5,
18 - Email 2020 258
Aug 25,
18 19 - Email 2020 259
Aug 26,
20 - Email 2020 263
Aug 27,
19 21 - Affirmative Defenses 272
22 - Second Amended Response to 274
Discovery
20 23 - 2020 Tax Return 283
24 - Bates 369 284
2 1
22 (Provided electronically to the reporter.)
23
24
25
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NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
1 REPORTED REMOTELY FROM BROWARD COUNTY, FLORIDA
2 TUESDAY, JUNE 22, 2021, 9:01 A.M.
3 *****
4 THE REPORTER: The attorneys participating in
5 this deposition acknowledge that I am not
6 physically present in the deposition room, and that
7 I will be this deposition remotely. °
reporting They
8 further acknowledge that, in lieu of an oath
9 administered in person, I will administer the oath
10 remotely. ° This arrangement is pursuant to the
11 Florida Supreme Court Administrative Order No.
12 AOSC-20-23. ° The parties and their counsel consent
13 to this arrangement, and waive any objections to
14 this manner of reporting.
15 Please indicate your agreement by stating your
16 name and your agreement on the record.
17 THE WITNESS: My name is Claudia Mathis.
18 MR. WILLIAMS: ° no. ° Not Claudia.
No, no, you,
19 We have to agree -- The lawyers need to agree that
20 we're taking the deposition in this way.
21 THE WITNESS: Sorry.
22 MR. WILLIAMS: ° Since I just Aaron
spoke,
23 Williams on behalf of the Defendants, and we agree.
24 MS. JONES: ° Amanda Jones here with Alex
25 Rosenthal on behalf of the Plaintiffs, and we
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NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
1° °agree.
2 MR. ROSENTHAL: ° there's feedback. I
Aaron,
3 don't know whether you're in --
calling
4 MR. WILLIAMS:° And just before we get started,
5 Michelle, I see you just called in. Can you mute
6 your phone just so we don't get any feedback?
7 THE REPORTER: ° Is that or...
sounding better,
8 MR. ROSENTHAL:° I don't know.° can you
Aaron,
9 speak again? He's frozen now.
10 (Audio interruption.)
11 MR. WILLIAMS: ° I don't know -- I don't know
12 what was said in the last about 45 seconds.
13 MR. ROSENTHAL: I know, you were frozen
14 while -- We were just to see if you had
trying any
15 feedback when you spoke, that's all.
16 MR. WILLIAMS:° I think it was when
Yeah,
17 Ms. Kaufman called in.
18 Michelle, if you can mute your phone just so
19 we don't get any feedback. I think that's where it
20 was coming from.
21 MS. KAUFMAN: ° I muted it. ° It's been on mute.
22 MR. WILLIAMS: ° Okay. this keeps
Alex,
23 happening. ° I'm to in and call and
going log back,
24 use the phone audio with the video because I --
25 something is wrong with mine. It keeps on going in
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NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
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June 22, 2021
1 and out. So give me two seconds.
2 MS. JONES: ° Okay.
3 (A recess was had.)
4 THE REPORTER: ° Would you raise your right
5 hand, please.
6 Do you swear or affirm the testimony you are
7 about to give will be the truth, the whole truth,
8 and nothing but the truth?
9 THE WITNESS: ° I do.
Yes,
10 THEREUPON:
11 CLAUDIA MATHIS,
12 having been first duly sworn or affirmed, was examined
13 and testified as follows:
14 DIRECT EXAMINATION
15 BY MS. JONES:
16 Q. ° Good Ms. Mathis.
morning,
17 A. ° Good morning.
18 Q. ° If you could please state and spell your name
19 for the record.
20 A. ° name is Claudia M-a-t-h-i-s.
My Mathis,
21 Q. ° And your date of birth?
22 A. ° 2/23/69.
23 Q. ° And your address?
24 A. ° 17647 Brook Boca Florida
Holly Way, Raton,
25 33487.
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FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021
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NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
1 Q. ° Have you ever had your deposition taken
2 before?
3 A. ° I have.
4 Q. ° When?° How times?
many
5 A. ° A few times for -- A few maybe
times; three,
6 four times.
7 Q. ° So you know how this works. ° You have to
8 respond verbally to all my questions in order for the
9 court reporter to take a record, correct?
10 A. ° Correct.
11 Q. ° So tell me a little bit about those three or
12 so times you've had your deposition taken before.
13 A. ° I had had -- I was a witness to an incident.
14 I was involved in a lawsuit. I was also another
15 witness to a -- an incident years maybe 19
many ago,
16 years ago.
17 Q. ° So tell me a little bit about your lawsuit
18 history. ° Have you ever been a plaintiff or
personally
19 a defendant in a lawsuit?
20 A. One time, I have been.
21 Q. In what county?
22 A. I believe Dade County.
23 Q. And what was that case about?
24 A. That was a discrimination case.
25 Q. And were you the plaintiff of the defendant?
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NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED
EXHIBITS NYSCEF: 01/05/2022
June 22, 2021
1 A. ° I was the plaintiff.
2 Q. ° Is that case or has that
currently pending,
3 resolved?
4 A.° It is resolved.
5 Q. ° And how ago was that case?
long
6 A. ° Several years ago. ° Five -- five years
Four,
7 ago, something like that.
8 Q. And who was the defendant in that case?
9 A. I have an -- I am not allowed to speak on that
10 case. ° I have a and I am not
confidentiality agreement,
11 allowed to speak on it.
12 Q. ° Okay.° what about civil
Now, any litigation,
13 have you been involved in, with respect to any of your
14 businesses?
15 Have any of your businesses that you've been
16 involved in ever been a plaintiff or a defendant in a
17 lawsuit?
18 A. ° No.
19 Q. ° What about are you involved in any pending
20 civil litigation other than this case?
21 A. ° No.
22 Q. ° What about or Expedia?° Your -- The
Regroup
23 companies, have they ever been a plaintiff or a
24 defendant in any civil case?
25 A. ° have not.
No, they
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FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021
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NYSCEF DOC. NO. 34 Claudia RRECTED RECEIVED
AS TO EXHIBITS NYSCEF: 01/05/2022
Mathis°7
June 22, 2021
1 Q. ° Have you ever been arrested before?
2 A. ° I -- I was arrested one time
Initially,
3 because I was a victim of identity theft, but that was
4 not a complete arrest. ° I shouldn't -- That was a
say
5 mistaken identity arrest, and that was in 1999 when I
6 changed name back to marr- -- maiden name.
my my my
7 And I was a victim of identity theft, somebody
8 ID. ° And a nightmare. ° That's before
using my big long
9 the internet, but I did a lot of work to clear my name.
10 So technically, yes, but not for myself, personally,
11 no.
12 Q. ° Got it. ° Have you ever been convicted of any
13 crimes?
14 A. °
Preview
FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Document 47-2 Entered on FLSD Docket 08/06/2021 Page 1 of 700 NYSCEF DOC. NO. 34 RECEIVED NYSCEF: 01/05/2022 EXHIBIT FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page2of700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 IN THE UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA Case No. ° 9:21-cv-80160 PATRICK GORHAM and NORTHWEST PACIFIC PROPERTY MANAGEMENT, LLC, Plaintiffs, vs. MICHELLE KAUFMAN, CLAUDIA MATHIS, and EXPEDIA FINANCIAL CONSULTANTS, INC., d/b/a REGROUP PARTNERS, INC., Defendants. O O O - CORRECTED TRANSCRIPT - DEPOSITION OF CLAUDIA MATHIS APPEARING REMOTELY FROM PALM BEACH COUNTY, FLORIDA Pages 1 through 298 Tuesday, June 22, 2021 9:01 a.m. - 3:55 p.m. Stenographically Reported By: Amy Lyon APPEARING REMOTELY FROM BROWARD COUNTY, FLORIDA U.S. Legal Support | www.uslegalsupport.com FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page 3 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1 REMOTE APPEARANCES: 2 ON BEHALF OF THE PLAINTIFFS: 3 Greenspoon Marder, P.A. 200 East Broward Boulevard 4 Suite 1800 Fort Lauderdale, Florida 33301 5 954-491-1120 Aaron.williams@gmlaw.com 6 BY: AARON T. WILLIAMS, ESQUIRE 7 ON BEHALF OF THE DEFENDANTS: 8 Rosenthal Law Group 9 2115 North Commerce Parkway Weston, Florida 33326 10 954-384-9200 Alex@rosenthalcounsel.com 11 Amanda@rosenthalcounsel. com BY: AMANDA JONES, ESQUIRE 12 and 13 ALEX P. ROSENTHAL, ESQUIRE 14 15 ALSO PRESENT: ° MICHELLE KAUFMAN - Telephonically PATRICK GORHAM 16 17 18 19 20 21 22 23 24 25 U.S. Legal Support | www.uslegalsupport.com 2 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page 4 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1 INDEX TO PROCEEDINGS 2 Remote Deposition of CLAUDIA MATHIS PAGE 3 Direct Examination by Ms. Jones 6 Certificate of Oath 294 4 Certificate of Reporter 295 Witness Notification Letter 296 5 Errata Sheet 297 Certificate on Corrections 298 6 INDEX OF EXHIBITS 7 PLAINTIFFS' EXHIBITS PAGE 8 NO. DESCRIPTION 9 1 - Fictitious Name 17 Filing 2 - BizFund Contract 37 10 3 - BizFund Settlement 40 4 - Capital Contract 45 Broadway 11 5 - Capital Settlement 47 Broadway 6 - Website Screenshot 71 12 7 - Email 121 8 - Email 137 13 9 - Email 148 10 - Contract 152 14 11 - BizFund Lawsuit 170 12 - Cash Statement 191 Petty 15 13 - Bates Stamps 402-453 196 14 - Complaint 225 16 15 - Payoff Spreadsheet 241 16 - Email 2020 244 Aug 4, 17 17 - Email 2020 256 Aug 5, 18 - Email 2020 258 Aug 25, 18 19 - Email 2020 259 Aug 26, 20 - Email 2020 263 Aug 27, 19 21 - Affirmative Defenses 272 22 - Second Amended Response to 274 Discovery 20 23 - 2020 Tax Return 283 24 - Bates 369 284 2 1 22 (Provided electronically to the reporter.) 23 24 25 U.S. Legal Support | www.uslegalsupport.com 3 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page 5 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1 REPORTED REMOTELY FROM BROWARD COUNTY, FLORIDA 2 TUESDAY, JUNE 22, 2021, 9:01 A.M. 3 ***** 4 THE REPORTER: The attorneys participating in 5 this deposition acknowledge that I am not 6 physically present in the deposition room, and that 7 I will be this deposition remotely. ° reporting They 8 further acknowledge that, in lieu of an oath 9 administered in person, I will administer the oath 10 remotely. ° This arrangement is pursuant to the 11 Florida Supreme Court Administrative Order No. 12 AOSC-20-23. ° The parties and their counsel consent 13 to this arrangement, and waive any objections to 14 this manner of reporting. 15 Please indicate your agreement by stating your 16 name and your agreement on the record. 17 THE WITNESS: My name is Claudia Mathis. 18 MR. WILLIAMS: ° no. ° Not Claudia. No, no, you, 19 We have to agree -- The lawyers need to agree that 20 we're taking the deposition in this way. 21 THE WITNESS: Sorry. 22 MR. WILLIAMS: ° Since I just Aaron spoke, 23 Williams on behalf of the Defendants, and we agree. 24 MS. JONES: ° Amanda Jones here with Alex 25 Rosenthal on behalf of the Plaintiffs, and we U.S. Legal Support | www.uslegalsupport.com 4 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page 6 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1° °agree. 2 MR. ROSENTHAL: ° there's feedback. I Aaron, 3 don't know whether you're in -- calling 4 MR. WILLIAMS:° And just before we get started, 5 Michelle, I see you just called in. Can you mute 6 your phone just so we don't get any feedback? 7 THE REPORTER: ° Is that or... sounding better, 8 MR. ROSENTHAL:° I don't know.° can you Aaron, 9 speak again? He's frozen now. 10 (Audio interruption.) 11 MR. WILLIAMS: ° I don't know -- I don't know 12 what was said in the last about 45 seconds. 13 MR. ROSENTHAL: I know, you were frozen 14 while -- We were just to see if you had trying any 15 feedback when you spoke, that's all. 16 MR. WILLIAMS:° I think it was when Yeah, 17 Ms. Kaufman called in. 18 Michelle, if you can mute your phone just so 19 we don't get any feedback. I think that's where it 20 was coming from. 21 MS. KAUFMAN: ° I muted it. ° It's been on mute. 22 MR. WILLIAMS: ° Okay. this keeps Alex, 23 happening. ° I'm to in and call and going log back, 24 use the phone audio with the video because I -- 25 something is wrong with mine. It keeps on going in U.S. Legal Support | www.uslegalsupport.com 5 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page 7 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1 and out. So give me two seconds. 2 MS. JONES: ° Okay. 3 (A recess was had.) 4 THE REPORTER: ° Would you raise your right 5 hand, please. 6 Do you swear or affirm the testimony you are 7 about to give will be the truth, the whole truth, 8 and nothing but the truth? 9 THE WITNESS: ° I do. Yes, 10 THEREUPON: 11 CLAUDIA MATHIS, 12 having been first duly sworn or affirmed, was examined 13 and testified as follows: 14 DIRECT EXAMINATION 15 BY MS. JONES: 16 Q. ° Good Ms. Mathis. morning, 17 A. ° Good morning. 18 Q. ° If you could please state and spell your name 19 for the record. 20 A. ° name is Claudia M-a-t-h-i-s. My Mathis, 21 Q. ° And your date of birth? 22 A. ° 2/23/69. 23 Q. ° And your address? 24 A. ° 17647 Brook Boca Florida Holly Way, Raton, 25 33487. U.S. Legal Support | www.uslegalsupport.com 6 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSD on Docket 08/06/2021 Page 8 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1 Q. ° Have you ever had your deposition taken 2 before? 3 A. ° I have. 4 Q. ° When?° How times? many 5 A. ° A few times for -- A few maybe times; three, 6 four times. 7 Q. ° So you know how this works. ° You have to 8 respond verbally to all my questions in order for the 9 court reporter to take a record, correct? 10 A. ° Correct. 11 Q. ° So tell me a little bit about those three or 12 so times you've had your deposition taken before. 13 A. ° I had had -- I was a witness to an incident. 14 I was involved in a lawsuit. I was also another 15 witness to a -- an incident years maybe 19 many ago, 16 years ago. 17 Q. ° So tell me a little bit about your lawsuit 18 history. ° Have you ever been a plaintiff or personally 19 a defendant in a lawsuit? 20 A. One time, I have been. 21 Q. In what county? 22 A. I believe Dade County. 23 Q. And what was that case about? 24 A. That was a discrimination case. 25 Q. And were you the plaintiff of the defendant? U.S. Legal Support | www.uslegalsupport.com 7 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Doc ent 47-2. Entered FLSDonDocket 08/06/2021 Page 9 of 700 NYSCEF DOC. NO. 34 Clau la Mathis° CORRECTED AS TO RECEIVED EXHIBITS NYSCEF: 01/05/2022 June 22, 2021 1 A. ° I was the plaintiff. 2 Q. ° Is that case or has that currently pending, 3 resolved? 4 A.° It is resolved. 5 Q. ° And how ago was that case? long 6 A. ° Several years ago. ° Five -- five years Four, 7 ago, something like that. 8 Q. And who was the defendant in that case? 9 A. I have an -- I am not allowed to speak on that 10 case. ° I have a and I am not confidentiality agreement, 11 allowed to speak on it. 12 Q. ° Okay.° what about civil Now, any litigation, 13 have you been involved in, with respect to any of your 14 businesses? 15 Have any of your businesses that you've been 16 involved in ever been a plaintiff or a defendant in a 17 lawsuit? 18 A. ° No. 19 Q. ° What about are you involved in any pending 20 civil litigation other than this case? 21 A. ° No. 22 Q. ° What about or Expedia?° Your -- The Regroup 23 companies, have they ever been a plaintiff or a 24 defendant in any civil case? 25 A. ° have not. No, they U.S. Legal Support | www.uslegalsupport.com 8 FILED: NASSAU COUNTY CLERK 01/05/2022 10:14 AM INDEX NO. 611469/2021 Case 9:21-cv-80160-DMM Document 47-2 Ent red FLSD on Docket 08/06/2021 Page 10 of NYSCEF DOC. NO. 34 Claudia RRECTED RECEIVED AS TO EXHIBITS NYSCEF: 01/05/2022 Mathis°7 June 22, 2021 1 Q. ° Have you ever been arrested before? 2 A. ° I -- I was arrested one time Initially, 3 because I was a victim of identity theft, but that was 4 not a complete arrest. ° I shouldn't -- That was a say 5 mistaken identity arrest, and that was in 1999 when I 6 changed name back to marr- -- maiden name. my my my 7 And I was a victim of identity theft, somebody 8 ID. ° And a nightmare. ° That's before using my big long 9 the internet, but I did a lot of work to clear my name. 10 So technically, yes, but not for myself, personally, 11 no. 12 Q. ° Got it. ° Have you ever been convicted of any 13 crimes? 14 A. °