Exhibit,Appendix: BEAUGRAND, IRIS vs. O'TOOLE, ROBERT

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                                Filing # 90126769 E-Filed 05/25/2019 09:21:48 AM

IN THE CIRCUIT COURT OF THE TWENTIETH JUDICIAL CIRCUIT
IN AND FOR CHARLOTTE COUNTY, FLORIDA

CIVIL ACTION
IRIS BEAUGRAND, individually and as
POA for Heidrun Riedner,
Plaintiff,
v. CASE NO: 2017 CA 181
ROBERT O’TOOLE,
Defendant.

Exhibit

Volume III of Transcript of Sarasota
Proceeding

1}PageFiling

 

73790145 F-Filed 06 19/2018 03:31:31 PM

 

The THELES
TH AND FOS SARA

 

   

SERRANO,

 

soREST

  

 

  

  

   

   

 
 

 

 

 

  

 

 

 

 

   

 

 

    

   

 

 

 

A haa
HONORARLE
STENOGRAPH ICALLY REPORTED 3Y
AMY E
eqigtered Professional Reperter
seporter
No, TC.
ze
INSEZ OF PROCE
‘ hy Mee 2
hy Mee 29
6 WITNESSES FOR THE PLAINTIEE/|
PRIS. REAUGKAND,
5 by Mr. Wiilioms 50
75
5 180
345,
by ir 299
wy by Mr 231
:
a POR THE DECENDANT/OUnTER-PLAINTIFF
5 RORERT O'TOOLE
6 by Mrs ¢ aa
t 301
4 byt 310
by Mr. xilliams 35
1 cLosiNe NTS
22 by Mr. Wit iams 387)
y Me. Clark 373
24
oo] cenrter 1B REPORTER ae

 

 

 

 

 

REKTS REFORTING, THC
441-085-726"

 

 

 

22

23
24
25

 

APPEARING

APPEARING

APPERR:

 

ON BEHALE OF PLAINTLFE/COUNTER:

 

WILLLAMS,
Williams,

 
 
  

 

ON BEHALE

PANT /c;

   

BRET CLARK, Esquire
Bret Shawn Clark, P.
ras.

 

  

 

 

BERTS REPORTING, INC.
941-485-

 

 

10
ul

 

Number

 

 

BLAINTIFE'S EXWIRITS

beseripyion Intrgduced Received

 

 

 

  

beed to Bayshore Property 63
nteust and Regions st eo

Mortgages

Oeed to 808 Let Street 64 6

Sales Contracts to Buy es ea

B08 ist Street Property

Power of Attorney o1 22 "i

Heidrun Riedne!

Lease Regarding Gallery 162

anat

Emails Between Parties 261 ad

Regarding Gallery Unit

Horse Registration Paperwork 444

and Receipt

note ‘Agreament Lo Pay a 6

beposition Transcript of 295 30

Defendant wath Exhibits

   

 

   

 

Progress vockot 138
copy ef Judgment vas 199)
Certificate of Delinquency

Copy of Satisfaction of 183 199
Judgment Payoft

Copy of Settlement 290
Agreement

Copy of Receipt tor Funds 295 29a
Composite of Wire Transfer 248

fron Heidrun Riedner

Conposice of Reaugrand sap

Checking Account Documents

 

ROBERTS REPORTING, INC.
941-489-926"272 me
1 1 DEFENDANT'S EXHIB 2
sunber reduced Received 2| xumber Description nduced Received
205, 205 3 P Child Support 6 ny
Case Payor! fron
‘ 4 Support Enforcement
244 PE Ent
| 0 child Support Enforconent : 19
os Satisfaction of Jeagrent
98 ‘
R nvary 2008 Regs 2 tae
3 3 98 7 Bauicy bine
" e| ¥ —_-2017 Property Appraiser ish asa
Sys 36 oe Profile sheet
9
4 2141/24/18 Bait Removing iss asa
. oe rr] Beaugeand as Buye!
22 Addensum Removing Beas Ms
00 as Purchase
rea
23° «1iv20/18 Short Sale weg
8 ros 308 2 Agreement
sa] aaL sing Stavenent
to | akZ Pana Title Comm tment is
o7 wel is rol Daves 1/11/15
‘ cure Complain 16
: ae 7 5: ARB Decenber 2018 sate ts
: 1 oF Payoff Reques: for 103108
O7 favor! Request : Rinna
18 . re AAA Lane 2025 Emails ‘To/Frot aw
/ . iw oa Benugrand @ fisher,
a ke: Orne
5 eb warranty Deed 10 O'T0ul iba sa
: tos Eefective 12/1818
a 2
“ te CC Handwricten Cd to Aeaugrand 18S 154
os 2 Bared 01/20/16
x ra 108 22[ pp 12/02/18 Questioned "Note" 155134
Pucportedly in Favor of Pinder
4 24
chil Support Engore: bh 109 EE Complaint. Filed by Buanazana :
Ms Case Payor! Request 25 For Rieden in Charlate County
THC. ROBERTS REPORTING, (NC
qes-7267
! 1 PROCERDINGS
2 vou 1
Profile Sheer "8 3 WE COURT: Good morning. AL ight. We
oC ther 2004 Need to [ris 73 98 pack « <
“ iris 6 Hans Wolfgang 5 Bogart -- Beaugrand versus Pobert Q' Toole, vase
e a De acs BS 38 6 number 2016-CA-6353.
HE ahwerker 2864 Koo on Hints 83 28 ’
8 with the deposition, or de T need to make Fame
oalasec3 yor 308
4 team Millsame 3 rulings?
> JELET Responsive Le aor ee x0 MR. WILLIAMS: bay Bout the
fron Clark
u u sections that I'd like ectered ince
Be S4/LDe1 Roltow-up better 401308
we from Ciack 2 THE COURT: Okay.
B Pun for Klaus to Le 33128 MR, CLARK: He just gave it te me now ang
Beaugrand uaced 07/23/
“ sith att idavs 1“ tim going throwah te, | should he done an a few
b copy ¢f Magzaaty 2 343 1
Big eres?
he 16 THE COURT: Okay.
w Assi Enait lo OTewie 0b 808
ans Y HR. CLARK: But we can proceed
us] 308 18 THE COURT: AlL right. Way don't we
1% proceed, and then maybe I'LL give you a Litule
Ww Notice te Produce 2
oo 5 20 bit of a longer morning break 4 have some
Ate Bark Receipts e237 a tine co have @ break snd qo “hrovgh those
“ 22 Okay?
Bn : os
7 a“ 23 MR. CLARK: Okay.
us| Sarasota County Permit ae 36 2a THE COURT: AlL eight. Me. o*Toole, why
thors 9685 208
2) 25 you take the stard again, and | wils
ROBERTS REPORTING, ZIIC. ROBERTS REPORTING, 21

     

Saieaee= 16 941

 

51267en
276 a
1 mid you thar yoy are © feom 1| ask you sore questions about that.
. yesterday 2| you were having problems payiny yaur rent of the
2S | aotice from my office, you were late sovera, months
a] pave anked your fami wut you did't 8
5| ve yor re 9 A. Okay
» hey a0 2. doula you agree with than?
a Q a AL Mes.
2 Ba 2 Q. And in addition te not paying the rent of
a] aot y 15) zhat commercial space -
vy) oan 4 MA. CLARK: Object son: Relevancy
5 4 THE COURT: Well, think that financial
te . 16 exchanges between the atts
be] pou we relationship are relevant 9!
5 & 18 this proceeding, so i'1! allow it, overruled.
: 19 YR. WILLIAMS: | Thank you
re | yo. nave 20 (BY MR, WELLIANS) And a
\ perry a1] you were in 20:6 you had not gad the
ey xo which you were supposed to pay
2 va ny the A rect.
4 renting from aus 26 ge And 9 you wete nehind iA those payment
, caso, but I'd Like to 28 5 to Klaus Gerke!
Nc ROBERTS REPORTING, ENE
941-488-1267
278 ne
L A : homae ngage than 1 exchanges, right, Mr. Clark?
was a lene. 2 MR. CLARK: Yeah, 2 quess That would be a
‘ @. kay. And it alse was -> as part of your 3 fair characterization
4 | understanding the commercial unit you a SHE COURT: And the exchanges with her
were wise sapposed Aoseuration tees as 5 parents have been interwoven i the purchases of
® a 6 properties, the BOB property and then the
corres . Gallery unit situation as well, 55 ~~
: And you han") paid ther, You were Behind 8 MR. CLARK: Right.
4} ik nose payment s 9 THE COURT: == you know, T think when you
‘ hb. 1 was behind several penths in these, 18 are asking the Court Lo make such a finding,
ni] corset u that it's incumbent upan me to 109k a the
fe > to say you were havane Einancial 12 entire pieture.
te} dirfseuity at che time you weren't being able to pay 3 MR. CLARK: Bight, neon
sa] your rent, Assuciation tees, and taxes Of the iy } think che Lime frame that we're discussing now
2 as is after they separated and they were no
16 Mk. CLARK: I'm qoing to object again 16 longer == they were no Inger living nogether
: payed on the Court's ralisg. f think what he's and cohabitating.
s 1 they separated, if T 18 THE COURT: Right, bot thee:
a, Fenause this is post 19 Mr. O'fosle is in today 15 relevant to your
soph 8a te counterclaims because £18 pustit tor
1 Me COURT: LE f anderstand your n he's been left in alt of this and whee he
we cuunerslaims, pal of what 7au want the Court 22 tands today even is relevant
redo $s in a ponition of equity find thet 23 MR. CLARK: Okay. ell, P21 withdraw che
M bochow Miso Heaugrand kad induced or wrongfully 24 objection
raken advantage of Mr. OMfoole is these 28 THE COURT: Welt, you don't have oo

 

 

 

 

 

 

 

ROBERTS RRPORTING, ROBERTS REPORTING, INC.
941-485-261 bat -a6h= 128)Tilt sverrule ir fer the renord. 1] communicate chat to them, or no?

 

2 Re No. We'd 2

 

eady broken pp by ther

   

Exnibit

   

that's why che 3 G. Okay. I'd Like to show yor

 

     

relevant. 4) tets been marked as Plaintiff > a composite

 

get s+ that's why J beliewe ir

 

Williams, did you want to add 5 | exnibie. vo you recognize any of Une what appears to

   

       

 

 

     

 

  
 

     

   

     

        

   

   

    

 

    

6 6 between you and Klaus and Reidrea Riedner
p think an's rele. >
a circumstances are relevant a he The first one, Yes, the quosti
° the analysis of this guar, the claims in this g| do 1 recognize these?
} se x0 Q. De you recognise these:
u Thark you. Pleas! n Ae Three out of fone. 1 don't rauqnige the
\ none 12] first one.
ask ay 13 a You reroanine the page of
4] auestce the restal 1s] exnans
aiytieti® ated Phe tak for the A. Yes
sneer nad 68, KeLe You 6 ©. But you reccgnize the res. of Fahibie 1?
exe. peace ke How many pages is Sanibic 77
A. Noy not necess 18) the paper clip because i couldn't read it
us : ov entisnally weren't raking 19 0. Thece are nine pages in Byhibis 7
ea paynen 20 Re ny you case?
: wey Owedd ime motey tron mark 1 did on the vy  Sine pages
L Soba haus that Uuey owned ana 3 never gor paid 22 Be Yeah, Every one gut the tarsi ene,
s| ter can, so yine bo in my mind custity not 23) would say, page one.

   

2. Okay. And these are e-mazis between

 

hom because they oweil me money from -~

        

 

 

 

    

 

 

 

  

   

   

    

      

    

 

 

 

     

   

   

    

   

  

   

 

> ©. tad you ever tatk to s+ aid yourself and Klaus and Heidrun?
ROBERTS REPO! ROBERTS REPORTING, INC.
94.4885 G1-485-7267
282

1 E ones 1] "Kiaus, don'ts feraet that 2 worked in your house tor
a parents? 2| six weeks, eight hours a night after my other work.”
3 A. Correct 3 om, ae you're asserting ~~ you's
4 And in these exmerls and letters between 4[ inferring that that means, "Klass, you ow me money"

thie tac ef you they're t about moneys you owe 5] there, even though you're telling ~ felling you
| csum in e916 in 2087? 6] you owe rent?

A Tho iast one on the Spyfa was on money he > AL correct.
# than Was your +s it that was the word 8 Q. Okay. And when he's providing -- 1s
° ~ 9| giving you money simply at the end of Exhibit 7, that
1 S Well, last page talc the cent 20] doesn't count for any consideratian for you helping
1 nit owl, at Lalks about money he lent oe at | him out with the work that you aid?
ae} you te starr a simpas 2 A. That was 10 years age that he gave me nhe
: ¥ 13] money.

4 oe 14 2. Okay. We're not asserting a claim for
6 He did not tend rhe ro ne, though. 1s] money in this case regarding that. We're Ju ying
ie] He qave we the money 16] that he's given you money over time. 8 sae?
Vt Qe Be que you the money? A. ke gave ne “> Tris Was going te
s e 18| Germany and he asked me if 1 wanted said,
4 2 ware you 19] "to, rt have -e stay here and work."
| expense within this 20 And he said, “How about if [ pay tor your
Lp whore xnibit V there's ne statement by you airfare and pay for your salary?"
2] saying, “naa You want me to pay rent? 22 So he offered to pay for my salary and my work,
ei | You owe me money for chis work that did." 2a| and I went te Germany for two weeks. He gave me
2a A. That's nor true. Tf 24] $5,000. He actuatty reimbursed me tor my airplane
gs] oon bree, (think it's Exh: as| ticker. £ think it was $3,500, $4,000 extra. And 5

     

 

 

 

 

 

 

ROBERTS

 

ROBERTS REPORTING, 11
941-485-7267Mu, WILLIAMS:

 

THE wzeNess

 

MR. WD MLTAMS,

   

fp evidence Exhibit

comet: Any

 

  

RE: Ne ebjenticn

Swill be

   

ng? Ang ee your

 

at yor made the

for the next e:ght years until

     

 

 

you say ke
be hay, Now) did you keep a running tot
fot how much ==
K, have canceled checks.

 

Okay, You've said that under your Direct

 

 

 

 

 

 

 

 

didn'* keop a writ a tuaning total of

 

 

  

 

 

 

ewe raght?
kay. Ana ie this the
parents are test giving You money, 35. walked
fn. They werent: giving me money. They
iit, Dukink, twice in 17 years.
ws We just talked about an instance, thovgh,

 

hat oreurred 18 years ag, $0

A. Courect, They haven't giver me any money

 

dn the last seven or eight years

sand Thad aske: diane

     

   

keen ur voument ag to a running total of how
Now

2. Wel), one of the reasons why you didn't do

that ig because yew quys were « ccuple and you didn'e

 

hhiak you bad tus

 

so certainty yeu didn't show any document

   

    

 

: y you owe me this * just remember.
. bkay. | Se youtre saying thet you talked

 

 

 

OMERTS REPORTING, INC

v4 -48)

 

 

 

 

 

Exan: vou Reng

 

nation. My question foe you is
like an accounting or running tora? of how mech you
thought Iris owed you?

AL Tn my head.

Q. Okay. So let me ask it a different way.

 

you didn't keep a written documentation as to how
much you thought she owed you?

AL No.

 

 

@. And you didatr = sertainty because
you didn’t keep that ducumentation, you never showed
cris, hey, I've made seven or eLaht payments, you owe

ne this amount of money. You never ~~ there was no

discussion about ~~

   

A. Yes, there was
G. But my question is you dida't keup «
written documentation
ke Noy TF did not seep a written
docunentatioa.
THE COURT: Hola ony AEH 6

 

 

Me. O'Toole, you cannot in

 

or rupt

 

 

when he's asking the quesrians. You have 6
him finish because ante tales af dow
okay?

THE WITNESS: i'm sorry.
0. (BY MR. WILLIAMS) My question was you

 

 

 

ROBEETS RRPOR!
Sa4l-aas-

 

 

many times that she owed you money

 

document, any e-mail of any aature

 

statement?

A. I didn't have a tendency to send e-mails

 

to my girlfriend, We usually -- we tived with each

other, so we would talk

 

0. So the answer to my question is there is

no document of any nature w!

 

ch suppor

 

statenent that I had discussions with Tris about a
this money she owed me?
AL No

2. Now, in your counterclaim you're asserting

 

 

that you made all these payments on Pinto amd you

 

wouldn't have made them but you guys were using tne

rent of Bayshore to pay the mortgages on Bayshore,

right?
Ae Correct.
Q. So if you're not living at Pinta, youtre

 

living somewhere. Yeu'd have to pay rent aomen

 

right?
©. Have you made a determination as ro if

chere's even any equity in the Bayshore house?

 

A. Have 12) No

©. Do you know what I mean By che term

 

 

 

 

ROBERTS REPCATING, TNC
941-485-1267288
meguity” 1] in 2017 -- oe Let's say 20:6 when you guy
a Yes 2] ae was $365,090
3 THE COURT:
4 ause 1 thought you were iy bans bet
5 you showed hin Unis document, absut Cayshore.
6 MR, WILLIAMS: Maybe I'm -- mayor I"ve
7 fused myself. Oh, hy Hm cating
c And you've basing That opt 8 Pinso
° tine oer standing ot the 9
: ne 10 ves, ye
: 2 - Ay in u you qoys were diving in Pinte,
ta ¥ nets 2 so Tim pear ~ ves
hae nisluneied the ni Honer. Tr was @ late oid
weeny ono a second THE cavRT: 7 mighe have wi noe
youre talk 18 burt thought when you asked Mim i: there was,
rik equity that you were asking about“
Me. WELLES ae r property. cle, were You answer EME abo!
, ob, 18 the Bayshore about the Pinte
: eG Mi wha re property?
niobis BY, the Property Appreiser has the property 20 THE WITNESS: Abou: the Bayshore property
1] qoina sinws in value by $69,008. Would a THE COURT: Okay. ALL right
a @. (BY MR. WELLIAMS) Asking about the ~~
2 1 aaventt seen it, 23 he Tima little eontuses. ust can you
‘ ve MEL) show you real quickiy jost fe the question?

  

28 0. Yeah. Ler me back: rack @&i pause just a

 

 

ROBERTS. KEPORTING

5, TUG.
94i-4ab- 1267

   

 

 

 

     

 

      

 

   

 

      

        

   

 

 

   

   

   

  

 

 

      

 

 

 

 

 

 

299
a] seen Um tald.na about the Psate property. Okay? 1| you some questions about the 808 Let Stceet house.
>) Your understanding, based on whan you've Just seen én 2| okay?
s| your svidence that submitted, tne Pinto 3 Sure.
4 tty hus decreased in valve from 7008 to 20177 4 Just we've done Pinte and Baystiore, 80
- oe hat the apprasser's office says on 5| wetre talking about 808 [st Street. 1111 show you
| a pice or papers ye 6 | exnibic 14. Sir, that document is trom thy seller om
And you c outers s co determine >| ene short cate of the HUH Ler Stree hinge. Me you
el arcs iny equity is the Piste preperty 8| recognize that as being ou
5 s 9 A. That's a letter fron Seteras ro Yr. James
Se oe presents 10] Sennelio, who was the previous owner of ihe BOE
M And you mato no attempts te decermine if there 11] Bayshore house
iz] was any equsty in the property in 2016? 12 0. Chay. In that lerter it says that there
s 13] came a teanster by the buyers of the property et ‘he
‘ ‘ by Nequity"? The 14 | 808 Ist Street house within * vote
| morta 1p] transaction
» h 16 MR. CLARK: Objection to counsel
. 1 testifying as to what the te
. 1 speaks for itself.
18 2 marked a8 19 THE COURT: Okay. Overruled
2 Piaamiffts 14 20 0. (AY MR. RILLIAMS) Ts that your
1 MR. CLARK: Counsel, do you have another 2i| understanding?
2 wet 22 k. Restate the question, please
Mi. wILLIAME: oA, your copy. 23 Q. Was it your understanding that the buyers
a CLARK: kay. 24| of the property -- you were the initial title buyer
GY of the 604 1st Street property?
ROWEPTS REPORTING, INC ROBERT

   

5 REBORTING, THC.
1287

541 -405— 941-485-726292
Q man Phe understanding between you
fs ornat sou were aeong to Lake in jointly
keviies Mie purchase uouk of your
rane
. hy tor her to get a real
petany : le to the property
5 Aud thar indicating that there
beg transfor of the property winnin 3¢ days of
that invtsas tiong is that your understanding?
2 te tea wetter games
its net a cetter te 1m
hat <= that was several yeare aye, but was it your
Gut transfer the property
eo kuyer -- cinie owner but
iris explained rome. T
cid tat sce thas letter.
took Trig's wore on it. She was the
TING, INC.
294

 

 

yo
thet
Phe aays

 

 

  

end 2

 

rom Heidvan Rieder

 

 

« to receiving ==

 

gate on thi

rete in German. TTL!

BEAUGRAND: You

 

tay MR. Be

  

tasty adicates Mar

bore an account

 

of thar?

 

 

No. J think Ud rome
okay

(neve prec
Haare ney co mm

 

 

 

ave {ies the day,

syage the dates are

ch idth, 2013, 10,900

led un your name

 

 

 

 

 

41 aet= 2

 

 

 

 

 

   

   

 

   

    

 

    

   

     

     

 

    

 

 

 

 

 

real estate agent. done what rode and 1 dia
as instructed

a ou what's been marked ar
Exhibit 15 fo Exhsbit 15?

No.

©. Exhibit 28 is a receipt for an exerow
depasit and it indicates Iris beaugrand paid a £5,000
deposit for the 808 + nous ints pay
the escrow deposit for she aoe tat .

do not remember it 1 ane cic

it, f never saw that piece cf paper be

a it possible she could Rave pasd the
escrow deposit?

he ts at possible? Yes but at
jeint account
deposit?

Re ts possible. don't ramen :
wrote the check or she wrote the check

a show you what was marked as
Exhibit i0. ir! Exhibit 2 1 bit
10 in thin case is the depo: tpl, ane
Exhibit 10 of the deposition transerspt +> snew
that to you. it's a one-page =+ or two pages. ints
a composite exnibit, two pages. Do yos recognize

ROBERTS REPORTING, INC.
941-485-7267
235
AL Yes.
Q. Okay. Now, the secans page of ~~ 5

 

was a gift of 10,900 euros in 7011?

5 thousand do

   

a en thonsand dollars: kay. AN

 

second page of the exhibit metre talk.ng about a

August 17, 2011, $4,178, What were those moneys for?

A. Can I see that again, please?
Q. Sure.
Rh. This doesn't say it was sent to my

 

account. There's no -+ my name in not on that piece

of paper anywhere

 

A

on there, ['ve never seen thet be

 

Oo. You

 

transfer of moneys by Klaus and Heidrun to y

 

$4,100 on August 17th, 2011?
A. They could have deen reimbursing me for
airfare, but f do not remember that exact wire

transfer from Heidrun,THE CLERK: >:

 

here you are,

 

dy have ald. 16?

 

 

me. wiLcaMs: T waula

  

 

 

P was admitted yesteraay, so

  

THR COURT: Seay

AR. CLARK: feo, bu!

ene ALL cian
hem indi What ied

 

 

bitsenendenne, and then

 

okay

 

 

 

ur

evidence

 

 

 

know which

Let's go through

 

 

 

 

 

wAjeet to it, although Thy

abort 20 mina

 

ago tert
THE COURT: Okay

MR. CLARK: This is

two and two copies Cf page two of a fivepage

sont Lem

 

 

Tie SOURT: Okay

 

Vite aseumpiete and uncer

completeness shud bave

 

being admitted.

 

  

 

The first page, the fir

 

 

 

 

And what is 14?

 

 

 

 

 

vagthy letter

first page that indscates that the

 

amitted over your

monet going =

 

ust been shown it

ast tame.

= it is page one of

agreement and it's

 

objecting wo iv at

 

additional pages

 

© page.

the third paragraph

 

 

ROBERTS REPORTING,

 

94. -485~

 

 

 

 

 

relevancy ef it. And the other th

 

 

this is not the proper witnes!
what this is.
THE COURT: Okay

authenticity and {ind that the document at

 

point has act been authe

 

cated. So

Mr, Williams, certainly of you have a wisness to

 

cali henticate in, Lo wici revasat the

 

ral

 

 

ARKt AS TO

 

worth this has

 

THE COURT: What is 18?

 

MR, CLARK: 1

 

  

ut doennte prove ma any

think inte -- the qoestion was did oot

 

5 prove that oy

 

   

paid the $5,900, which in does not slo that.
L think it should be =~ [tm guing tu object to

THE COURT: T think that goes more towards

   

your arqunent of what the Court should de with

 

 

the information thas the admi ss

 

 

 

CLARK: Okay, ALL right

THE COURT: Go T would say -> that's Loy

 

ROBERTS REPORTING, INC
941-485-7261

 

 

 

299

 

property can't he transieried withia a) days.

of this letter.

 

‘that's the only purpos

 

cel of the transaction sf the

 

it was pect and

 

398 propert

have re see phe whole

Ma. CLARK

 

agreement. You can't pull out ty paces ot a

five-page agreement and say ~~ ana interpret 11

in that fashion. How do you know that the

 

aren't other clauses in ‘Rat contract that say
something eise?
MR. WILLIAMS: Very unlikely. the aly

issue that this decument is offered for 19 the

 

 

to unat it was a 0-day window ot time, nor 90

days.

 

THE COURT: 1 think bis Lesrims:
think Mr. C'Toole essaniially agreed to that.

50 based on the rule of completeness I will

 

sustain the objection and act admit Exhibit ~
MB. CLARK: 14
THE COURT: <4. Thank yout

MR. WILLIAMS: 1 have no further

 

THE COURT: Okay. et?

 

MR, CLARK: I've got one exhibit betore T

proceed. We do have a stipulation as te the

 

 

RIG REPORTING, INC.
941-495-7267

RoR:390 4
: wos rip 1 THE CLERK: Rud se Fase pages wnnth eed
2 Tuk COURT: Chay. 2 to be physically removed
MK. CLARK: And there's @ iist of the 3 THE COURT: Right just admit the
: tha has proffered, and we have no 4 whole exhib twill find that the Courr
. roue the of pages: was . not consider the porwions that are act
® kind enough to type uP the - 6 Listed on the List any of thine o> any
Tie COURT: Thank you. > objection nade by Ur. Clark is being sustained
® a and the by 8 MR. CLARK: Okay. I'm going to “> pardon
be wa we have ne objection te 9 me. Cant approach? PP, 09 and RRL They were
‘ “ Pet 16 marked and not admitted for ung tat a
n THE COURT: Okay. So what 2 will do re To think 1 signed something and you qave these
ry back to ne
on was 3 TMB CLERK: Are reintroduce
4 adit ExnIBIT a4 then?
ae - 1s MP. CLARK: fes, yess <
q he ut y hier the sections that 16 ving then back to
lowal on the ducumant ents clad Robert r THE CLERK: They wil! pe Label 20
5 ” o: sary iach, 2018, 18 and BR.
. ec curt onsider any of 19 MR. CLARK: hile he's doing 1 can
228 thet ie not issted cn this list. 20 ask some questions co save time
» Me. pogaest ayer a an COURT: Okay
: pocndina that Go the exit REDIRECT EXAM:HATION
23 BY MR. CLARK:
‘ 4 a poole, you testified a momant 390
25] abour the deposit -- the escrow deposit for the
302
1 1 MR. CLARK: Xs.
2 2 2. BY MR. CLARK) ls you recognize PP)
: notieve yeu testified chore was a 3 kT do.
oo a 4 And what 15 0
fs correct 5 hk. iets a letter sent to me by Mr. Williams
‘ dl you expiaia to th what that 6| of vacating the premises. 1 was getting kinked out
count was and what it was £ >| of my business =~
® he intially -- we've a.weys had separate 8 Q. And what's the date?
a cnevking accounts, Weld never hud a faint checking 3 R= Location.
y | asco the anole vise aw hen we 10 Q you just reed for the benefit of
rif awesnet rs purchase a non cen up al Li | court the dase on the tetcer?
joant checking are mint, and Iwas te pur o> we sete 2 RK. The date of letter is 2/4/2027
dara put my and Heidrun's money Seto that a Q. And what is your -- could you please
ra | aecounr and 1 for tne ist Surect house 14] deserite to the Court what happenea?
5 at for anything €ise 1s Well, first let's back up for a monent. What,
° he ist Street house 16] was the approximate date thar you separated fron
te you rer act tne escrow iv] tis?
rs} aepas se het acount? 1B A. August 2018.
5 Ke Yow, ot was 19 2. Would you please descr ite how +
ne 26] happened?
4 hk. Trig was gone away for == she Look a 0b
2 Mi. CLARK: Let me show you PP, 00, RR. 22| working nights as a dog-sitter and she was gone every
2s White he's reading raat, do you have the 23] night for @ week supposed y dog-sitting, an she came
3 narand-bet-yetstorbenadmitied cite 24| home one day and said, "It's Lime Lo teave."
Ss i CLERR: fo de. XK, 28 Se grabbed ny clothes and my wioe == 1 howe al
ROBERTS REPORTING, THC ROBERTS REPORTING, IC.

 

‘94 in485- F267 941-485-7267did you take with you?

 

 

My clothes and ay wine. =

 

   

    

Chay. And at the shop what was happening

    

 

1 as ay existed
comal. traffis petwenn yeu and Kise =~

 

 

aid Heidrin, end this tock place

  

   

what went wratt

   

 

on and Kiaus regarding the sp

 

 

our business out of.

 

 

yove Tact any paperwork. 1

 

 

 

 

 

 

 

306

 

 

wi aiaat have than, I

 

hecaht you suid BE,

cos

 

ARE: Yas in victory.

3 [AY MP, CLARK) ould you please describe

 

cunert we
x a letter from [ris to myself. You
font! want ne had the whole letter, do yo

 

Wel) =

 

 

she's qumancing money:

 

 

 

    

   

 

 

 

Q. 0 Wharts the date that it was sent by her to
you?

A duly L4nh, 20:

3 That” 4 ne forward

oh September 15, 2016.

v Did you, un ) tecerve that enmail?

>. Bid you respond to that?

A 1 odontt bet

G2 And why not? Why aidn't you respond?

 

L wus ridiculous statemente thet she

 

 

 

 

 

  

 

 

   

 

 

y| just got @ Letter fron He. #
2 Q. Sut -= okay.

3 RK. don't understand Ub Are you
4 ng to PP, OG, RR?

5 9g. No. tim ref ain :

6) guess ints 7. Plainvattts 7

7 A. And the question

8 @. You wore asked one ghoar that e-mans

   

 

9| traffic, and t's

 

 

Year. This was in Wed

 

 

11| december 2016 e-mail tx

   

ffic between mys

12| Heidran. Fee

 

q sorry about

 

ne preawiny up. T

13| read che e-mails. 7 seen ther.

 

pe 2. Ar that pe

 

jn bime did it shear ta you

1s} chat you were going to have to maybe teave Che

 

 

16| premises

1 AL Yes.

 

Q. And then you reneived

 

letter from

 

19) Mr, Williens asking you te leave?
20 A. Corsect,
OQ. Okay. Let me shew you Bxhibis A and atk

22) you to take a look at that

MR. WILLIAMS: What exhibir are you

 

te

24 MR. CLAR ‘ow

 

25 MB. WILLIAMS: WV.

 

ROBEPTS REPORTING, 1

 

Se

 

2 Q. Okay. Let me show yau what was marked for
2 as WW

3 NR. WILLIAMS: didnt: hear you.

4 MR. CLARK: WH.

5 MR. WILLIAMS: oh

6 0. (AY MR, CLARK) D0 you recall receiving

that document?

a AL do nor
8 Q. that ds chat? Whar is thet document?
10 A. It's a letter from Mr. Williams to myselt

 

ii] on November itch, 2016, stating the

 

 

12) representing Iris Beaugrand and he's waking dematy

 

13| co sell the propertie
14 Q. You don't recall having received that

15] tetcer?

   

16 he Noy I received i sun: received
ye] ate okay?

18 Q. What's the date of it aget!

19 BR.  11/17/2026

20 @. Did you respona ty that a chat

   

ai] time?

 

22 Re Wo
23 Q. aay not?

24 Rk. I belaeve 2 cailed you
28 2. Okay.

 

 

bo
ROBERTS REYORTING, INC
941-485-7267308 303

attorney. T have 1 all be admitted. Thank you

 

     

    

 

     

   

    

      

   

iptorneys: Randle e 2 MR, CLARK: FP, Q0, are we
e ailing me did you respend in 3 going to get 4 list ater?

i) any way -- 4 CLERK: Yeah, T can give you 3 S3pyy

io. 5 sure

* -- he 6 MR. CLAKK: Okay. Thank ye
any regen why? ° THE CLERK: And with that, al. of tbe

5 A. tts ieqai stutt. 1 let lawyers handle 8 exhibits that you had that were not = that were

ledat state 9 ID'd only? There were a couple t
ghay. 1 dont 1 have 10 take those back as w
: yuythana further ul MR. CLARK: Yeah. Well, T have three
CRT: Okay. AL. tight. Thank you, cy hen. T can give you this nue back because it"

Hr Nite, 13 pet ==

4 THE CLERK you 14 THE CLERK: And what about these two?

y nek ate you aS MR. CLARK: These? Tim going To pe using

       
   

 

   

Me. oA ke to move then sast likely
thew Yr tHE CLERK: Vary gucd ou et
4 : believe vhey were, 18 THE COURT: Okay. AND rial clark,
RAY 38 go you hy other witness?

        

 

CLARK: Yeah, I de. I'd like to ce!

 

1 eqavdina the evicth a Teis Beaugcand ro the stand

 

   

THE COURT: ALY right

 

ho ck lection. No ebjectic 23 Miss Beaugrand, : would remind yoa that. you're

   

eo oath as ye.

     

Bay of unm Okey. They will as) as

 

 

 

 

 

 

 

     

   

        

     

 

        

 

    

 

      

         

 

   

 

 

 

 

 

      

 

 

 

 

 

 

 

ROBERTS REPORTING, TIC ROWRAYS REBORTING, LHC
a= 48b~ 941-485-1267
310
L) cesmexeon, L Q. That's -- stop right there
{cB AN 2 ke t= from the date of this norase 7"
moe) sus ced an an adverse witness by the defendant 3 g. Step, stop.
i] and, baying been previewsly duly sworn on oath by the 4 THE COURT: Go ahead and str
s | clerk of Sureeit Curr, testified as faliows: 8 you to vead the one seritence.
. DIRECT PXANINA’ é O. (RY MR. CLARK) Thank you. ake
MR. CLARE >| one snep at a time. That first sentence. Would you
» D2 Sood morning 8] agree with me thar you were asking him to
Goma morning. | che house to take you off Lhe mort gaae?
' © n tu show you what has bees moved 19 hk. Correct, 1 did that.
1] sate evidence as Exnibit Vv. you to take a look n @. And what about rhe equity Line? The
le P 12] equity line was not mentioned
ty 1 wrote that Le 13 ke Tt was in both ~~ ip beth debts. There's
M4 S. You aide a * ra | not tust one dept
yoae > the paragraph, that 2. Okay, So your intent in saying that
ft re bayshore." 16) that you wanted him trance Lhe peaporty and
he nehee 17 | take your name off of the debt for both the first ant
« 5 wid you pleasé read that sentence? 18| second mortgages is that corseer?
a hk. As it eeluten Cu the home on Bayshore 19 A. Correct,
2a | tick we are bork vane k since the loan is 20 Q. is chat sumetbing wat you're still
1] city sn my name, as you were unabie to quailty due 2i | seeking in tnis -- in this case at this Line?
ya) ro gus: poor credit rating, that you refinance it in 2 Ae No. When? hat letter, Tike
your nane enty so that 1 at ne longer responsinie for 24) mentioned in that Lerter, it was a very abasive
raf any dots sncurred. Tf ° unable 9 accomplish 24] relationship. I went to counseling, 1 Saw e
this antain vO days = 25| counselor who advised me that I have ty get cur acd
REPORTING, 2C ROBERTS REPORTING,

   
 

941-485-726)312 ba
Ll sey tee So whet he walked out on me =~ 1 2. Fargon me?
7 | whe ne stared is wrong, tow, when he said T lett 2 Ro J was seared of mim, [wasnt ty be out
i | tin. : did noe leave nin, He He had 3] of that relationship and pa dune, and § thouehs that
: exp salts 4 give him ue Lite ao qutoe, but he
Fie, 5] aian’t respond and he just started with chests
‘ : < 6| and --
a ’ . — Farden me te raten that lost
. Luever suid te ham he has te leave. 8 ALE said but he respons ro that
5 Qe Okay, ALL right, So you're | tester, so Thad to involve a lawyer and we had te 99
; kowas apusive. fb Wal of him, ana 20] through ait che Lies and everything.
toe 2 get ai] or of jegai fees, My credit a ruined
ser pth fet 12) nave the income fron ot heant
ands he 13| let of things nave changed, sv this ia re
wel ny 1s | anymore. Thay was becau seed an
wees is] ger out quien, but it didn't banpen
hp cattos. pays < re une $1,900 8 16 g. wha that emsel
reuth cenant we ws to get when we > Ae Yes. and T aise roma
nls fied letter to hin
ut . . 1 @. The date that -- can fa chat the
poe Ke axe both 30 | date of September 18 at 6:00 p.m. us correct?
4 : a k ect
2 : re that 22 0. Row goon after you sear yo
pos wrens so get oa] this lecuer -- this email?

    

        

 

 

 

 

 

 

 

 

           

   

 

 

 

   

 

 

 

    

       

     

        

      

                  

 

 

 

    

       

 

 

 

 

 

 

a] your same at A. 1 tried te betore contact vin phone to
in. T wanted U3 be == see if we can sit together and ~-
KOREN REPORTING, INC ROBERTS REPORTING, UC
bar-4nb— 7267 341-485-7267
314
: : : soking how Teng 7+ how Loni i Ang you're sayina that
ol after te tert the house was it tha you seat this 2| August when you had this -- when you separated?
oP mass 3 Ae Yes
i we 29 srtean, 20 days, 18 days, 4 @. Between thea and Septenber 15th?
. Lowes tw) or tarey weeks after he left? 6 @. Aud Row mony fimas cid he sone bare
A - AL Lcanty tel. you sxactiy how many
“ G. 0 Rad that wae = | ke came several tines. de picked up sone ef mis
: AL Be stilt cane on Lhe property to pick 9| cars. He had like 13 cars, tho boats, & neat traizer
j | up tina when ne said he thas was o> ints 10] be nad rented out to somebody acd cos lected the rent
a die cane back on the property several times ti | fe had Like 90 old Cures Stored on my prapeety, and
au ok up has belonginas he had the garage full of his thing of the
i 2 2 wast tbat? 13] garage he picked up picked up, Tike 1 saidy my
5 Seprenber ista ard August 2 14| wine collection what was worth $17,000, bar he pa
vj an ee when he deft. Between this 15] pur the amount. of that on because he had located ite
e | came he sure numerous Uines te pick up sone of nls 16| 1 had gotten i: froma German frieno. ie
no sidntt ~ ay wine Internet antenna down, even that ~~ the [nserr
miieut ion he stole and his he alse cook @ 18] company says that belongs to the house. He cant’
wT tot oto cf the qurage. He took his 19) take at down, so he came back and took that te
of ones 2o| broke ey air conditioning regulates thernoata:. When
. 4 second so we 21 | 1 brought ny car to repair, somebody said somebody
get the fou weeks before 22| cook a hanmer to it.
eprent cowaii you had 23 2. Wait for a moment, You're say:e
. lett? 2a] this took place between A -
25 Re Before The @-mat tent the
RORERTS REPORTING, INC ROBERTS REPORTING,

 

D41na@E~ 24 8

 

5-485-12671] semaity 1] e-mail, this statement that youtre now making that
G0 And 4.4 you tiie a porte « 2| came to your nouse and took 1? cars, 12 or TS
we 3 be dign't taze all of them, There was
1 Sow 1 bess 4 ) some he picked up Tater where 1 pat nis
pe fp xouli have said he belongings in after he refused. 1 did ask Rim to
6 be Raa jou said be had 9 6| please cone, pick up = we had in that nema
waneg Beat? >| giso belongings he claimed it was tiny Hell, some!
: uake Ld cas, Lowen vay 22, 23 cars, 50 s| agreed, Other ones whese L didn't agree, what i hod
| rrras kad to gut rid of and pay off, 01d tires ne 5 thar ermail,
kect any Ae pat them lie said, 10 Q. Chay, wkay, $9 Lette boone step
1) weit trash. it would a] a tome. agree with ne that you didnt
1 - computer stuff on 12] mention anything in this e-mail about him coning back

     
       

           

      

         

 

bos ae jut my space for somebody 3 1
if te oe Peat tea 1 feted that 14] or sone of them and poate and an on ay tne ether

a] osouts rear nis act xo beets, 15 you Just now menticned

ef ster 6 have the wACLE = yeaty
i ‘ we] fp do. Wels, 7 have Reve, "7 have asked —- on

c[ this tee numerous occasions have asked you te re ’

” belonging (sic) from my property."

fos 20 Okay, That's not the que:

 

   

they were atl his a1] bur does + re anything about your

   

     

      

     

 

 

 

 

   

 

   

       

      

   

 

   

 

22 jest today that he was soning to yor house
2 BR es vowan Ie care. Maybe 11 23 at sate?
ra} oost 24 Please can jou read the question?
se Aad is mentioned anywhere in this 28 Q. Does the e-mail state anywhere in your
fot
KOAERTS REPORTING, 1 ROBERTS REPORTING, TNC
Da L-Aab= 126 ‘941-485-7267
nk
L | cemest a complaint of a sranoment describing what you i] lett.
avi cust pow testified Nere today that he was coming 2 a first one being 4 boat with trailer?
5] back amg forth onto your property ard cemaving things ke Yes
apa ay and so cn and so ferth during this 4 ©. Okay. Se he didn't: => obvicusly he didn't
period 5 | pur the trarier and tie boat in w vehicle?
f A ‘ Re No. That woud oe = he aide
8 explain ‘chy you did not meation it >| respond to any kind of conversation, phone call,
a| in the mast? e| texts, e-mails, 1 had sent the certified fetter. In
® he tet me readl it peeause Im not o> well, 9] the petween time when he moved our to That ermal
a) then i have seid Rim that want him on the 10] there were only two cars epparently left, so ne

   

 

F the

 

 

 

na that Tran hav 21] picked up al! che other ones. Biot

 

ty

       

     

       

     

 

 

      

    

   

        

       

thie conail, correct 12| broken down, 89 @ few Teck ame ob and eft ay
1s . t In the wemsil you ee List 9 number fe Stith had Left na, vahaates. He bad
ps nat hart 14] tne boat with trailer, T had che twa cars, another
is| boat trailer, co pressure washer, tools, jacks,
te G. And on page twa, tne second £ 16| clothes, alcoholic drinks what he wanted, fisp ot],
ast ventence, you state, "You must let me 17} baking mixer, passport, files what 7 sili had, the
le you will be these sa that you can sign a 1a[ cuko (gin) for the TY. ALL of that f put into the
y| rere ior | have picked up all that a9] two cars
5 tego te yout 9. You pur o> E mean, | ater
oriect. 2i| obviously you didatt pur in there 5, Lav! sh
ge hier testified, and then 22| jack hes, alcoholic drinks. Way that the sine
a ny whiga ¢ have pur into your twee 23| that you were talking abeut?

     

A. No. The wine wag my wine pioned up. He

 

 

hohum, se the ro vehicles that were had some other alcoholic drinks. i knew what

 

 

 

 

 

ROBERTS REPORTING, TNC
942-488 726320

         

     

   

   

, iacey fo don't arink. Aleokolig deis 1) is not true, He Look a Let files
The wines Ge took was mine. That was the 2| Thad an the attic, and i can ever prove that pe Foor
1 ping Re the house kecavse it had 3] ny files because sone cf papernoré he claines 2s

i} vais jack an an comail ro me that he wants 4) evidence he had sent te => or you had sent te Stwele

|| mis cther aleohetig beverane, 5 whatever we bad s| wiliiens were paperw fry Hie

       

   

 

       

«| sivoans house 1 pat in the cars, too. 6 9. Which wauld he whar?

1d | mad asKea fin to please com so that Z - b Chat was phe where he stained
s oon ancw se i oat have somebody there 8 Which would be what 4
, es sate woth ae where hy sin sign everything o] wnat documents you say?

        

 

inte che twa cars, 10 A. Absolutely. We have it there, zight,
at | mr. williams? Yeah, } think T have is there. A

we truck came and 12) Letter or come cf evidence yo

    

he property even 23] witiiams =~

  

   

    

   

       

        

 

 

 

 

   

 

 

    

 

  

 

 
    

 

 

       

a]ou alion it te bin 14 2. Could you fasatify ~~
S| oor ny Kate sala a tow truck drive 18 B what cane at
ne henn i. They te Bs feat on the 16 3. you identify any ot it
property. ‘they wae anyway and took a8, So all of B Ac Yeah. bo you went me to get in? Yea, 7
a] othe a were in there, the past the files. 18| can
a : You pul ne of the 9 9 1 wowid, actually.
» ered vehic k t can
1 a a ALL eight. Why
i yet (he pasapurt ? 2 vhis we take « break and M
‘ rat ¢ tex Files ne at 23 Beaugrand can go Warougr shone documnts, a
4| ay none, Most of my tiles ne actually took and he 24 then you can ask her the question again whee
J] claims he didn't. But 7 nave all tis files? That 5 she's had tine to refresh her memory. And you
ROBERTS HEPOW ROBERTS REPORTING, iNC
Salen 4 indBb- 1267
Fe
32 2
1 ant your testimony with your attorney, i MR. CLARK: Wet r
2 bet you can certainly review docaments on the 2 TH COURT: Okay. Po you want
: break 5 she hes you vate 1
4 nw vkay ‘ continue?
He COURT: Al. fight? Thank you. her's 5 NP. CLARK sure
’ eo ant need an 6 sri COURT: up to you af you nent o
nalenind Dreak because you've already had time > break. We've been going for a iittie over an
B he go over Mr. Williams dee-gaations for the 8 hove, so we can goa little bit more if you
9 des You did than? 8 want. Let's continue
mec Yeu have an ey (Discussion between Mr, Wiitians and Mr.
n ‘ clark.)
We COURT: 1 nave 2 MR. WILLIAMS: Wetre not on the record,

  

      

 

THE COURT

 

so for an approximate 15 (off-tne-record discus

   

 

 

 

   

   

   

1 oneshour meet ing 16 the following proceedings were hall.)
Mm. CLARK: Se I'm hoping that we cen be . TAR COURT: Hold ea. Before you taiky
* ene ry the 1 let's go back on the record
: He Counts aire nut, 1 ean have you 19 THE WITNESS: "Towle sent
FOL ome tans afternoon. Bat [tm hopeful 20 THE COURT: old oa. Please auntt Lalk.
L hot poet Jone by meen aa So we'll be back on the record. Although 1 was
geay. 1 uhink we wt 22 guing co give Mise Beaugranil tame ty rewiew Une
: AML rignt. oy don't we == 23 documenta before the quescinn was asked againy
4 Lheve it. J have it right 2a she was able to locate it, so weTIE rontinee
here 28 without a break at pornt

 

 

 

 

 

 

     

LNG, THe

SS RERURTING, .
1261

Gat-ags- "267 941

REPORT
485-de uust, Mee Clark, T Caink the question

  

ling

apinet that were then sent to you in discovery

 

the first pase.

  

st the first page?

  

 

Stecle Williams

   

   

   

 

   

 

 

  

 

 

 

  

   

 

 

 

  

 

 

ron what we put into the
. we a se We dost
(Me. Clark ==
hier. So the
WR. CLARE: ene
Hy COURT: Ne. het me finish without
‘ niesrapted:
tik COURT: The question is what documents
aM augrani purporting weee taken from her
NG, INC
326
gh
PRE COURS: ==
point EE has been tdentitied by the

Witness aS an answer to your question, Yoo nay

ask toiiow-up questions If yon choose oF aot.

2 (ey MRL CLARE) La the exhcbit, the
Sonpasite EXHIDL! RAR, whet you claim to be docy
provbiced ny my office 1 ye

© oescrine for the
Mp. Gtiwole that ne cam 9 the 898

wosid say itt

Toe

   

a proposal,

    

 

    

re iu hae the are of Tet
Trail, this was a file f had as a realtor

y howe te y wax a listing of

rae pang the buyer was Nacey and

 

 

 

inc

 

 

 

4
5
6

 

 

 

 

by Mr

 

Mroole that were Chen provided in
discovery by Mr, Clark cu Mr. Witla,

And she was giv

 

 

identify what documents that magkt be. She went

and retrieved a document from her table and her

 

coraey, so at this point Jet's have the

 

 

kind of a> ds che

 

chree pages you're holding resate te cack ethers

Should they be ore extiibit?

    

 

 

THE WI should ket ee
hig is a page ~~
THE COURT: Main. Okay. stop there

 

for a secend.

 

thine pages

AE CLERK: Ther will this be

   

or plaintiff's?

MR. wr

 

LANs: Not mine.

  

THE COURT: Okay. This will be =

yeferdant's ex

 

we're up Lo BRA.

   

CLERK:
THE COURT: ARE
MR. CLARK: Rel!

 

  

plaintiff's exhibic, but
THE COURT: Heil, you asi to
identify, so -- it's not admitted, but when you

 

 

TS REPORTING, INC.
gL -48a~ 7267

 

 

had

 

gin Trivisans, and se

 

nothing to

 

 

808 ist treet house

removed fron my house with several other real

 

files, transactions, when Mr. O'Toole moves out

 

MA. CLARK: itm going te oPject to the

witness testifying ag te things where she has no

 

predicate to state that it was removed from her

THE WITNESS: How did he ger int

 

couRT: we

 

MR. CLARK: The witness did net abserve

them being removed trom her hy

  

testify that these documents we
her house.

THE COURT: Okay. PA

 

you asked ber to

name the documenta that she was claiming ~~
ce. CLARE: Tes

- removed trom hee

WE COURT: has bes:

house by Mr. O' Towle

so in that guesticn she

   

 

ering the 4 he

   

  

that you asked.
MR. CLARK: But she's embellishing and
adding information acd testifying as To an event

  

that she did not witm

pred:

 

cate to add to the questinn askes by saying

 

ROBERTS REPORTING, [NC
544-485-726e-mail, you include

 

2

       
  

MR. CLARK: I would shrec

 

 

THE WITNESS: ‘There was nor much Left
MR. CLARK? Object. The answer is
aresponsive. i'm asking the question ~~

THE WITNESS! i went through "he

 

 

THE COURT: Hold on, held be
obiects I have to rule

THE WITNESS: Okay. Sorry

THE COURT: All right. Sustained. G9

 

ahead and re-ask the

 

hat you anewer strietiy wnat his quest

 

   

. es that you List ax

 

   

one of the you Placed ints two ¥

the list, whar files were those?

 

ALT dont recall exactly what it There

 

were a few folders, so when [ skimmed through the few

 

folders that were left at my house 1 went through

every paper. whatever was related to Mr. O'Tooie, T

 

 

 

 

 

 

 

 

 

 

 

 

328
on ig are these
Le secure 1 were produced by ny
THE COURT: ALL right, i'm goang te
chat her arswer directly relates and is in
fore the questisn that you asked, $9
wit, everra sh nd certainly
you can argue nnat you've mede in
fe. CLARE Ser
wrt t than those three
: xduied By my SPtive to
ther paparacré coming te
Gere Wi biiané, BUL it Proves my point when
eject jest te the witness
arguing.
TUB COURT: Okay, And sustained
. (RY MP. CARE) The dist of in your
NG, a
330
box, neta andy don't

         

 

vy. How many tyles cr are these file folders?
A wasnt! mpen t he took already

  

  

 

   

 

“ boleh there
a rexumate number ef pages?
A Foeantt tel! you Row many. It was 2ike

hat mock {indicating} in a box, iacluding is

 

ind other personal iters

 

De Are there any other items at Pinto tha

 

and they shouid be returned?

 

 

 

he Nothing. Everything was
6 No #unt Jeninas?

 

Heid on, You ail are talking

   

 

 

 

ROBERTS KESCRYING, IC
54s-4aS~ 726
a
a (AY MR, CLARK) Paantings? Artwork?

 

testimony that you put those

 

things cars, of that they just -- yeu don't

 

have them, or that they don't belong ro him?) Wiich
of those three things?

A. 1 don't have anymore. He took a Io! of

 

 

things. whatever was left, ( put ay

have nothing left at my property

 

 

O. Bid he take any paintings, artwork?
A. fe Look -= yee. | wasn th watetiing him
when he left. He was so anery, I was soared of bim,

and it took several days until he had removed
everything. So yeah.
oo. Is there any artwork at your house thet

belonged to bin?

 

A. Ne
@. 1s therm any a aL all?
Ah. AE my house?

a Yes

A. Yeah, but avthing from him.

 

 

@. So there are some paintings ~~ is it fair

 

to say that there are some paintinus ar your house,
bat you state that they don’t belong te tin. They

helong to your is that correct?

 

 

 

 

RIS BRPCI
541-4 85~ 125"

 
 

ane.

Lot
ROBERTS REPORTING,
541-485-7267L 1 A. Edo not have the passpors of my nom
2| because she needs that Te teavel, and [ don't have
5 work trom ham 3] any o'tsele!s files or papers
2 kerr ne ot 4 okay. That's &
. iets yest eo A. Everything else © did give to Mr. steele
‘ seat? 6 | wintians, He has a lot cf my bank statements, as
ve baal yr o1 the Notice te >] much as I could go Back with the bake. Me has ay
3 fee ar e| cax returns for the last 10 year he has all
5 és 6| that paperwork. Yes, wy do have that.
. this dotice ta Produce io @ ALL right. Letts just
ul. fooy er using documents wath you clarify the record and te be
Rt 12) "Any and alt documents and th.
jie (hese docurents at this showing ail funds contributed by £
vf cise towards," and then iF Lists the propert ss
- individually
ue . 16 Ae T have that
vo} sam @. And are there aiat var
: : 18] are responsive ty tha ae
‘ A 19 | bring with you?
‘ ive to 20 A. No
1 bo a 2. Evezything that exists (hat shows payne
; ee, 2 dad 22| that you made towards the acpiistt ion and payment ot
you do rot expenses related to kayshore, for example
hat are daser.bed in the M4 A. AS far as 1 could go Lack.
Not ioe ue Bre 25 okay.
ROBERTS REPORTING, INC. ROBERTS REPORTING, INC
532-485-7267 941-485-7267
ce
saa ve
1 , ciateronts Gad tol Let me go 1 THE COURT: Okay. Lee's take var morsiny
back “ha 2 break, ard that will give you time to confer.
, 2. AD right 3 Hr. WitLiam:, do you have any
s os, 1 d2 have 4 questions for your chient
ae 5 SR. WERLIANG: 7 just have “ne question
. ° wa rough. tse te you, 6 COURT! Gu ahaad
guostion was are there documents in - CROSS FRAMINAT LON
ef os tat yoo don't have, 1s didn't bring 8 BY NR. KILLIAN
4 we 9 @. In response te that e-mail you sent Bon
te hh. There might be some docune 10| oftesle saying get your stuif off my property “> the
1 oe skay. Red van you identity ri] e-mail's seif-explanatery -- did he give you any
: where Thoge documents are response?
» MB. WILLIAMS! Yeoh. lake F indicated A. None Tate whan L contacted
14 yostersay, there's 4 box o ouk at 14] you
, by ant yo act Le Lock ah it yesterday. as Q. Further question: Did he ever responet by
® And Caeytre separated by high! ighted 16] saying you still have my stuf rhe removed all
sheers of paper, everything she's got as ta 17] nis cars trom your property?
every cateanry that you indicated, even if itts 18 Re No.
ww sot even spe y requested. TRatts what 18 MR. WILLIAMS: Thank yeu
he nas 20 JERK: Ang seal quick, Mry Clark
1 oe nave anything 2 stared ¥¥ was just for TE purposes
LM farses. Howeve Light of these papers 22 MR. CLARK: Righs.
~ wotre wither aing (9 have te confer with 2s THE CLERK: But BB =~ or, ox
i caste tn geing Ue save te call Bob © 24 was there @ suling ex it being admitted:
back te the stand. 25 THE COURT: 1 dentt Think erthe: party nas

 

 

 

 

 

 

 
     

ROBEETS REPIRTING, 1
485-25 941-485-796No objection

 

Guy count:

  

 

    

 

 

BARS
We COURT: COD wT be admitted
Mh. wT! Tra + speaks ¢
self, yeah. The C