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R. Leonard, C.S.R., Inc. Certified Shorthand Reporters 818.995.2449 SHEET 6 PAGE 21 1 BECAME THE CFO OF VINEYARDS DEVELOPMENT CORPORATION? 09:45:13 2 A JUST TO BE PRECISE, I BELIEVE IN 2009 SHE WAS 3 RACHEL FIANNAGAN. SINCE THEN WE HAVE MARRIED AND SHE IS 4 MRS. OGULNICX AND SHE, SAME PERSON, DIFFERENT NAME SINCE 5 2009. 09:45:13 6 Q WHEN DID YOU GET MARRIED? 09:45:13 7 A ARE YOU GOING TO SHOW THIS TO MY WIFE? MAY 8 24TH, I THINK IT'S '09. 09:45:13 9 Q NOW, YOU SAID THAT MISS OGULNICK OR MISS 10 FLANNAGAN WAS VICE-PRESIDENT IN CHARGE OF DESIGN; IS 11 THAT RIGHT? 09:45:13 12 A CORRECT. 09:45:13 13 Q WHICH C014PANY IS SHE VICE-PRESIDENT IN CHARGE 14 OF DESIGN OF? 09:45:13 15 MR. BISNO: OBJECTION. AT WHAT TIME? 09:45:13 16 Q BY MR. RUBINER: WHEN YOU SAID THAT SHE WAS, 17 WHEN YOU SAID IN YOUR PRIOR ANSWER SHE WAS 18 VICE-PRESIDENT IN CHARGE OF DESIGN, WHAT WERE YOU 19 REFERRING TO? 09:45:13 20 A FROM 2009 WHEN SHE BEGAN WORKING FOR MY COMPANY 21 SHE WAS TN CHARGE OF INTERFACING WITH THE ARCHITECT TO 22 CREATE ELEVATIONS, TO CREATE FLOOR PLANS, MARKETING 23 MATERIAL, INTERNET - SORRY. EXCUSE 14E. WEBSITE 24 MARKETING. 09:45:13 25 Q WHAT COMPANY? 21 F.4PAGE 231 CORPORATION HAVE AN OFFICE? 5:13 2 A HOME OFFICE. 5:13 3 Q WHERE IS THAT? 5:13 4 MR. BISHO: OBJECTION. RELEVANCE. 09.45:13 5 THE WITNESS: LOS ANGELES. 09:45:13 6 Q BY MR, RUBINER: DOES VINEYARDS DEVELOPMENT CORPORATION HAVE THE SAME OFFICE ADDRESS FROM 2009 TILL B TODAY? 09:45:13 9 MR. BISNO: OBJECTION. RELEVANCE, 09:45:13 10 THE WITNESS: WE MAINTAINED AN OFFICE IN PALM 09:45:13 11 DESERT SOMETIME IN 108, 109 AND 2010. 09:45:13 12 Q BY MR. RUBINER: SO IN 2008, 2009 AND 2010 13 VINEYARDS HAD AN OFFICE IN PALM DESERT? 09:45:13 14 MR. BISNO: OBJECTION. RELEVANCE. OBJECTION. 15 COMPOUND. 09:45:13 16 THE WITNESS: CORRECT. 09:15:13 17 Q BY MR. RUBINER: WHERE IN PALM DESERT WAS IT? 09:45:13 18 MR. BISNO: OBJECTION. RELEVANCE. 03JECTION. 19 VAGUE AS TO TIME. )9:45:13 20 THE WITNESS: 37600 COLLEGE DRIVE. )9:45:13 21 Q BY MR, RUBINER: WAS IT THE SAME ADDRESS THE 22 ENTIRE TIMME IT WAS IN PALM DESERT? )9:45:13 23 A IT WAS. )9:45:13 24 Q AND IS THAT THE DEVELOPMENT KNOWN AS THE 25 VINEYARDS OF PALM DESERT? PAGE 22 PAGE 24 09:15:13 1 A IN VINEYARDS DEVELOPMENT. 09:45:13 1 A IT is, EXCUSE ME. 09:45:13 2 Q DOES MISS OGULNICK CURRENTLY HAVE ANY OTHER 09:45:13 2 Q AND OTHER THAN AT THE VINEYARDS OF PALM DESERT, 3 POSITIONS OTHER THAN CFO AND VICE-PRESIDENT IN CHARGE OF 3 IN 2010 DID VINEYARDS DEVELOPMENT CORPORATION HAVE AN 4 DESIGN WITH VINEYARDS? 4 OFFICE AT ANY OTHER ADDRESS? 09:45:13 5 A IT'S POSSIBLE. SHE CERTAINLY DOES MUCH MORE 09:45:13 5 A JUST THE HOME OFFICE I MENTIONED ON OGDEN 6 THAN THOSE TWO CAPACITIES. I DON'T KNOW IF SHE IS 6 DRIVE. 1 OFFICIALLY LISTED ON A STATE FILING. 0 9 : 45:13 7 Q DOES VINEYARDS DEVELOPMENT CORPORATION PROVIDE 09:45:13 B Q IN 2009 WHEN MISS, THEN MISS FLANNAGAN BECAME 8 YOU WITH A COMPUTER? 9 CFO OF VINEYARDS DEVELOPMENT CORPORATION, DID IT HAVE 09:45:13 9 MR. BISNO: OBJECTION. VAGUE AS TO TIME. 1O ANY OTHER EMPLOYEES? 09:45:13 10 Q BY MR. RUBINER: EVER, 09:45:13 11 MR, BISNO: OBJECTION. RELEVANCE. COUNSEL, WHERE 09:45:13 11 MR. BISNO: OBJECTION, RELEVANCE INSOFAR AS THE 12 ARE YOU GOING WITH THIS? 20D9 IS WELL BEFORE THE TIME 12 QUESTION INCLUDES PRE-2010 ACTIVITIES. 13 MY CLIENT EVER MET YOUR CLIENT. 09:15:13 13 THE WITNESS: I -- I DON'T KNOW THE ANSWER TO THAT 09:45:13 14 MR. RUBINER: IT'S REASONABLY CALCULATED TO LEAD TO 14 QUESTION. 15 THE DISCOVERY OF ADMISSIBLE EVIDENCE CONCERNING 09:45:13 15 Q BY MR. RUBINER: IN 2010, DID YOU HAVE A 16 REPRESENTATIONS MY CLIENT CONTENDS WERE MADE A YEAR 16 COMPUTER THAT YOU USED FOR VINEYARDS DEVELOPMENT 17 LATER. 17 CORPORATION BUSINESS? 09:45:13 18 MR. BISNO: YOU MAY ANSWER. 09:45:13 18 A YES. 09:45:13 19 THE WITNESS: NO, NO EMPLOYEES. 09:45:13 19 Q WHERE DID YOU MAINTAIN THAT COMPUTER? 09:45:13 20 Q BY MR. RUBINER: SINCE 2009, OTHER THAN YOUR 09:45:13 20 MR. BISNO: OBJECTION. RELEVANCE. 21 WIFE AND YOURSELF, HAS VINEYARDS DEVELOPMENT CORPORATION 09:45:13 21 THE WITNESS: IN WHICH YEAR ➢=D YOU ASE? 22 HAD ANY OTHER EMPLOYEES? 09:45:13 22 Q BY MR. RUBINER: 2010. 09:45:13 23 MR. BISNO: OBJECTION. RELEVANCE, 09:45:13 23 A IT WOULD HAVE BEEN AT EITHER OFFICE. 09:15:13 24 THE WITNESS: NO. 09:45:13 24 Q DID YOU HAVE SEPARATE COMPUTERS AT EACH OFFICE? 09:45:13 25 Q BY MR. RUBINER: DOES VINEYARDS DEVELOPMENT 09:15:13 25 A NO, 221 24 Dalesandro vs. Ogulnick Deposition of Ryan Andrew Ogulnick, Vol. 1 August 13, 2012