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R. Leonard, C.S.R., Inc. Certified Shorthand Reporters 818.995.2449 SHEET 7 PAGE 25 PAGE 27 09:45:13 1 Q DID YOU HAVE A LAPTOP? 09:45:13 1 THE WITNESS: NO. 09:15:13 2 A YES. 09:45:13 2 Q BY MR. RUBINER: DOES VINEYARDS DEVELOPMENT 09:45:13 3 Q AND DID YOU USE THAT SAME LAPTOP IN 2011? 3 CORPORATION OWN YOUR COMPUTER? 01:45:13 4 A I DON'T RECALL. 09:45:13 4 MR. BISNO; OBJECTIONI. RELEVANCE. OBJECTION. 09:45:13 5 Q DO YOU USE THAT SAME LAPTOP TODAY? 5 VAGUE AS TO TIME. 09:15:13 6 A JUST TO BE CLEAR, I HAVE A LAPTOP. I DON'T 09:45:13 6 THE WITNESS: NO. 7 KNOW WHEN IT WAS REPLACED. I DON'T KNOW. 09:45:13 7 Q BY MR. RUBIN3R: DOES YOUR -- IN 2010, DID MISS 09:45:13 8 Q WAS IT REPLACED SINCE THE BEGINNING OF 2012? 8 OGULNICK USE A COMPUTER FOR VINEYARDS DEVELOPMENT 09:45:13 9 MR. BISNO: IF YOU RECALL. 0 BUSINESS? 09:45:13 10 THE WITNESS: NO, 09:15:13 10 MR. BISNO: OBJECTION TO THE EXTENT THAT THE ANSWER 09:45:13 11 Q BY MR. RUBINER: WAS IT REPLACED SOMETIME IN 11 CALLS FOR REVEALING ATTORNEY -- PARDON ME -- EITHER 12 2011? 12 ATTORNEY -CLIENT OR SPOUSAL COMMUNICATION. 09:45:13 13 A I THINE 30. 09:45:13 13 THE WITNESS: DIRECTING ME NOT TO ANSWER? 09:45:13 14 Q DID YOU RETAIN THE -- WHEN YOU REPLACED IT, DID 09:45:13 14 MR. BISNO: IF YOUR ANSWER -- IF YOU ONLY HAVE THE 15 YOU MAINTAIN THE -- DO YOU STILL HAVE THE LAPTOP THAT 15 ANSWER BECAUSE OF INFORMATION RECEIVED FROM SPOUSAL 16 YOU WERE USING PRIOR TO IT BEING REPLACED? 16 COMMUNICATION I'M DIRECT -- OR INFORMATION YOU RECEIVED 09:45:13 17 A NO. 17 FROM YOUR ATTORNEY, I AM DIRECTING YOU NOT TO ANSPIER. 09:45:13 1S Q WHAT DID YOU DO WITH IT? 09:15:13 18 THE WITNESS: I RECEIVED THE INFORMATION FROM MY 09:45:13 19 MR, BISNO: OBJECTION. RELEVANCE. HE TESTIFIED HE 19 SPOUSE. 20 DOESN'T HAVE IT. 09:45:13 20 MR, BISNO: I DIRECT YOU NOT TO ANSWER. 09:45:13 21 THE WITNESS: I DON'T KNOW, MY WIFE HANDLED IT. 09:45:13 21 Q BY MR, RUBINER: DID YOU EVER RECEIVE AN E-MAIL 22 I'M NOT SURE WHAT SHE DID WITH IT, 22 FROM RACHEL OGULNICK OR RACHEL FLANNAGAN THAT WAS ALSO 09:45:13 23 Q BY MR. RUBINER: IN 2010, WHAT WAS YOUR E-MAL 09:45;13 23 SENT TO MR. DA1ESANDRO? 24 ADDRESS? 09:45:13 24 MR. BISNO: I OBJECT TO THE EXTENT -- I'M SORRY. I 09:45:13 25 A RYANOGULNICKOHOTMAIL. 25 WITHDRAW THE OBJECTION. 25 1 27 PAGE 26 PAGE 28 09:45:13 1 Q DO YOU STILL USE THAT SAME ADDRESS? 09:45:13 1 THE WITNESS: NOT THAT I CAN SPECIFICALLY RECALL, 09:45:13 2 A NO. 2 ALTHOUGH I WOULD CONCEDE IT'S POSSIBLE. 09:45:13 3 Q WHAT E-MAIL ADDRESS DO YOU USE NOW? 09:45:13 3 Q BY MR, RUBINER: DID YOU EVER RECEIVE AN E-MAIL 09:15:13 4 A RYAN@VINEYARDSDC.COM. 4 FROM MISS OGULNICK OR MISS FLANNAGAN THAT WAS ALSO SENT 09:45:13 5 Q WHEN DID YOU START USING THE VINEYARDSDC.COM 5 TO MR. SCHOTTENSTEIN? 6 ADDRESS? 09:45:13 6 A YES. 09:45:13 7 A LATE 2010. 09:45:13 7 Q AND WHAT E-MAIL ACCOUNT DID THAT E-MAIL COME 09:15:13 8 Q DID YOU CREATE THE VINEYARDS DC E-MAIL ADDRESS? 8 FROM? 09:45:13 9 MR. BISNO: OBJECTION. RELEVANCE. 09:45:13 9 MR. BISNO: OBJECTION. VAGUE AND AMBIGUOUS. 09:45:13 10 THE WITNESS: NO, 09:45:13 1D ANSWER IF YOU CAN, 09:45:13 11 Q BY MR. RUBINER: WHO DID? 09:45:13 11 THE WITNESS: I DON'T KNOW. 09:1':13 12 MR. BISNO: OBJECTION. RELEVANCE. 09:45:13 12 Q BY MR, RUBINER: DID MISS OGUINICK MAINTAIN AN 09:45:13 13 THE WITNESS: I DON'T KNOW, 13 E-MAIL ACCOUNT ON THE VINEYARDS DC SERVER? 09:15:13 14 Q BY MR. RUBINER: DO YOU KNOW IF THE VINEYARDS 09:45:13 14 MR. BISNO: OBJECTION. VAGUE AS TO TIME. 15 DC -- STRIKE THAT. 15 OBJECTION TO THE EXTENT YOU CAN ONLY DIVULGE OR ONLY 01:45:13 16 IS THERE A SERVER THAT VINEYARDS DC HAS? 16 ANSWER THE QUESTION BY RELAYING INFORMATION YOU RECEIVED 09:15:13 17 A I DON'T KNOW. 17 FROM YOUR SPOUSE. 09:45:13 18 Q OTHER THAN YOUR LAPTOP COMPUTER, DOES VINEYARDS 09:45:13 18 THE WITNESS: YES, SHE HAS AN ACCOUNT WITH 19 DC HAVE ANY OTHER -- I'M SORRY. STRIKE THAT, 19 A -- WITH VINEYARDS DEVELOPMENT SERVER. I'M NOT AN 09:45:13 20 DOES VINEYARDS DEVELOPMENT CORPORATION HAVE ANY 20 EXPERT IN THIS MATTER BUT I THINK I ANSWERED YOUR 21 OTHER COMPUTERS? 21 QUESTION. 09:45:13 22 MR. DISKO: OBJECTION. VAGUE AS TO TIME. 09:45:13 22 Q BY MR, RUBINER: AND WHO AT VINEYARDS IS . 23 OBJECTION. RELEVANCE. 23 RESPONS13LE TODAY FOR MAINTAINING THE VINEYARDS SERVER? 09:45:13 24 PLEASE ANSWER IF YOU CAN AND IF YOU CAN PLACE 09:45:13 24 A RACHEL. 25 THE TIME. 09:45:13 25 Q AND HAVE YOU EVER OBSERVED MISS OGULNICK USING 26 � a Dalesandro vs. Ogulnick Deposition of Ryan Andrew OguUck, Vol. 1 August 13, 2012