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CORRESPONDENCE - NON-AGENDA
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City Clerk
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Agenda Packet
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9/1/2020
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SHEET <br />45:13 2 <br />45:13 3 <br />45:13 4 <br />4 5: 13 5 <br />45;13 <br />45:13 <br />:45:13 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />- PAGE 30 <br />15:13 1 <br />15:13 2 <br />3 <br />:45:13 <br />:45:13 <br />45:13 <br />45:13 <br />:45:13 <br />45:13 <br />15:13 <br />4 <br />S <br />6 <br />7 <br />8 <br />9 <br />10 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />17 <br />18 <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />R. Leonard, C.S.R., Inc. <br />Certified Shorthand Reporters <br />818.995,2449 <br />PAGE 29 PAGE 31 <br />A COMPUTER FOR VINEYARDS BUSINESS? F 1 CONTEXT OF AN EMPLOYEE? DO YOU MEAN IN THE CONTEXT OF A <br />MR. BISNO: OBJECTION. VAGUE AS TO TIME. <br />HAVE YOU EVER. THAT WAS THE QUESTION. <br />THE WITNESS: YES. <br />Q BY MR. RUBINER: HAVE YOU OBSERVED 14ISS <br />OGULNICK USING A COMPUTER FOR VINEYARDS BUSINESS IN THE <br />LAST YEAR? <br />A YES, <br />Q OTHER THAN THE COMPUTER YOU USE AND THE <br />C014POTER THAT YOU'VE OBSERVED MISS OGULNICH USE SINCE <br />2010, ARE YOU AWARE OF ANY OTHER COMPUTERS OWNED BY <br />VINEYARDS DEVELOPMENT CORPORATION? <br />MR. BISNO: OBJECTION TO THE EXTENT THAT IT CALLS <br />FOR REVEALING SPOUSAL COMMUNICATION. <br />THE WITNESS: AS I TESTIFIED BEFORE, I DON'T <br />BELIEVE VINEYARDS OWNS ANY COMPUTERS, BUT OTHER THAN THE <br />COMPUTER I SAW RACHEL WORKING ON AND MY LAPTOP I <br />MENTIONED BEFORE, THERE ARE NO OTHER COMPUTERS. <br />Q BY MR. RUBINER: AND HAS MISS OGULNICK CHANGED <br />COMPUTERS BETWEEN 2010 AND TODAY? <br />MR, BISNO: OBJECTION. VAGUE AS TO TIME. <br />OBJECTION TO THE EXTENT THAT IT CALLS FOR <br />REVEALING SPOUSAL COMMUNICATION AND I DIRECT YOU NOT TO <br />THE ANSWER TO THE EXTENT THAT ANSWERING THE QUESTION <br />CALLS FOR REVEALING SPOUSAL COMMUNICATION. <br />THE WITNESS: I DON'T KNOW. <br />Q BY MR. RUBINER: OTHER THAN -- NOW, YOU STATED <br />EARLIER THAT VINEYARDS DEVELOPMENT CORPORATION <br />MAINTAINED AN OFFICE IN 2010 AND OTHER YEARS AT 37600 <br />COLLEGE IN PALM DESERT; IS THAT RIGHT? <br />A CORRECT. <br />Q OTHER THAN YOU AND MISS OGULNICK, DID ANYONE <br />ELSE WORE AT THAT OFFICE? <br />A YES. <br />Q WHO ELSE WORKED AT THAT OFFICE? <br />A ROBERT WILKINSON AND EMPLOYEES OF THE <br />CONTRACTOR CW DRIVER AND MY BROTHER, JEFFREY OGULNICK, <br />Q AS FAR AS YOU'RE AWARE, DID ANY COMPANY OTHER <br />THAN VINEYARDS DEVELOPMENT CORPORATION USE THAT OFFICE <br />ADDRESS IN 2010? <br />A AS I JUST STATED, ROBERT WILKINSON. HE HAS HIS <br />OWN COMPANY, SUNTEK. CW DRIVER. I BELIEVE THAT'S, <br />THAT'S IT. <br />Q YOU SAID MR, WILKINSON'S COMPANY IS SUNIEK? <br />A CORRECT. <br />Q DID MR, WILKINSON EVER WORK FOR VINEYARDS <br />DEVELOPMENT CORPORATION? <br />MR. BISNO: VAGUE AND AMBIGUOUS. PLEASE EXPLAIN, <br />WHAT DO YOU MEAN 'WORK FOR," DO YOU MEAN IN THE CONTEXT <br />OF AN INDEPENDENT CONTRACTOR? DO YOU MEAN IN THE <br />2 PARTNER? <br />:45:13 3 Q BY MR. RUBINER: DO YOU UNDERSTAND THE <br />4 QUESTION? <br />:45:13 5 A I HAVE THE SAME CONFUSION MY ATTORNEY HAS. <br />:15:13 6 Q OKAY. <br />:45:13 7 WAS MR. WILKINSON EVER EMPLOYED BY VINEYARDS <br />8 DEVELOPMENT CORPORATION? <br />:45:13 9 . A NO. <br />:15:13 10 Q WAS MR, WILKINSON EVER AN INDEPENDENT <br />11 CONTRACTOR FOR VINEYARDS DEVELOPMENT CORPORATION? <br />:45:13 12 A NO. <br />:45:13 13 Q WAS MR. WILKINSON EVER AN OWNER OF VINEYARDS <br />14 DEVELOPMENT CORPORATION? <br />:45:13 15 A NO. <br />:45:13 16 Q ARE YOU FAMILIAR WITH A PROJECT CALLED <br />17 VINEYARDS OF PALM DESERT? <br />;45:13 16 A YES, <br />:45:13 19 Q DID MR, WILKINSON HAVE ANY RESPDNSTBILTTIES FOR <br />20 VINEYARDS OF PALM DESERT? <br />:45:13 21 A NOT FOR VINEYARDS OF PALM DESERT BUT THE <br />22 OWNERSHIP ENTITY, SINATRA & COON PROJECT LLC. <br />:45:13 23 Q WAS MR. WILKINSON EMPLOYED BY SINATRA COOK LLC? <br />:45:13 24 MR. BISNO: OBJECTION. RELEVANCE. <br />:45:13 25 THE WITNESS; NO. <br />PAGE 32 <br />13 1 <br />2 <br />:13 3 <br />:13 4 <br />:45:13 <br />:45:13 <br />:45:13 <br />45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />:45:13 <br />5 <br />6 <br />7 <br />9 <br />l0 <br />11 <br />12 <br />13 <br />14 <br />15 <br />16 <br />11 <br />1B <br />19 <br />20 <br />21 <br />22 <br />23 <br />24 <br />25 <br />Q BY MR. RUBINER: NOW, YOU SAID BEFORE HE <br />WAS -- WHAT DID YOU UNDERSTAND SUNTEE TO BE? <br />A SUNTEE -- <br />MR. BISNO: OBJECTION. VAGUE AS TO TIME. <br />THE WITNESS; SUNTEK, I BELIEVE, IS AN SPE THAT <br />MR. WILKINSON CONTROLS. I DON'T KNOW IF IT'S A <br />CORPORATION OR AN LLC. <br />Q BY MR. RUBINER; DO YOU KNOW WHY MR. WILKINSON <br />HAD AN OFFICE AT 3600 COLLEGE DRIVE AT, IN PALM DESERT <br />IN 2010? <br />MR, BISAO: OBJECTION. RELEVANCE. <br />THE WITNESS: IT ALSO MISSTATES MY TESTIMONY. <br />MR. BISNO: OBJECTION. MISSTATES THE WITNESS'S <br />TESTIMONY. <br />THE WITNESS: YOU SAID 3600. IT'S 37600. <br />BE WORKED OUT OF THAT OFFICE IN HIS CAPACITY AS <br />AN INDEPENDENT CONTRACTOR HIRED BY SINATRA. 4 COOK. <br />Q BY MR. RUBINER: DID YOU ATTEND HIGH SCHOOL? <br />A YES, <br />MR. BISNO: OBJECTION. RELEVANCE. <br />Q BY MR. RUBINER: WHERE DID YOU ATTEND HIGH <br />SCHOOL? <br />MR. BISNO: OBJECTION. RELEVANCE. <br />THE WITNESS: IN NEW YORK. <br />Q BY MR. RUBINER: WHAT HIGH SCHOOL? <br />Dalesandro vs. Ogulnick <br />Deposition of Ryan Andrew Ogulnick, Vol. 1 <br />August 13, 2012 <br />
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