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CORRESPONDENCE - NON-AGENDA
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City Clerk
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9/1/2020
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SHEET <br />4 5: 13 1 <br />2 <br />3 <br />:13 <br />; 45:13 <br />:15:13 <br />45:13 <br />45:13 <br />45:13 <br />15 13 <br />:15 13 <br />4 <br />5 <br />6 <br />7 <br />8 <br />9 <br />10 <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 />25 <br />R. Leonard, C.S.R., Inc. <br />Certified Shorthand Reporters <br />818.995.2449 <br />12 PAGE 45 <br />PAGE <br />THE WITNESS: I HAD NO EQUITY WITH THE KAPLAN <br />09:45:13 <br />1 <br />FAMILY. I HAD VARIOUS PROJECTS THAT WERE -- TREY WOULD <br />2 <br />BE JV'S AND WE'D ACQUIRE THE SITE TOGETHER. I'D BE AN <br />09:45:13 <br />3 <br />EQUITY PARTICIPANT. <br />4 <br />Q BY MR. RUBINER: THIS IS AT PC INVESTMENTS <br />5 <br />YOU'D BE AN EQUITY PARTICIPANT? <br />09:45:13 <br />6 <br />A I THINK, TO BE PRECISE, THESE PROJECTS WERE <br />09:45:13 <br />7 <br />ACQUIRED UNDER NEW SPE'S SO IT WASN'T PC INVESTMENTS BUT <br />8 <br />THE PRINCIPAL OF PC INVESTMENT AND MYSELF WOULD ACQUIRE <br />09;45:13 <br />9 <br />SITES AS PART OF A JV. <br />10 <br />Q BY MR. RUBINER: WERE YOU AN EMPLOYEE AT PC <br />11 <br />INVESTMENTS? <br />09:45:13 <br />12 <br />MR. BISNO: OBJECTION. RELEVANCE. OBJECTION, <br />13 <br />VAGUE AS TO TIME. <br />09:45:13 <br />14 <br />THE WITNESS: I THINK THAT'S ACCURATE, IN A DUAL <br />09:45:13 <br />15 <br />CAPACITY. THERE WAS -- YES, 50 THAT WOULD BE CORRECT. <br />16 <br />Q BY MR, RUBINER: SO YOU WERE, JUST SO I <br />09:45:13 <br />11 <br />UNDERSTAND, BETWEEN -- WERE YOU AN EMPLOYEE THE ENTIRE <br />18 <br />TIME BETWEEN '96 AND '98? <br />09:45:13 <br />19 <br />MR. BISNO: OBJECTION. RELEVANCE. <br />09:45:13 <br />20 <br />THE WITNESS: TO THE BEST OF MY RECOLLECTION. <br />21 <br />Q BY MR. RUBINER: AND WHAT WAS YOUR JOB TITLE? <br />22 <br />MR. BISNO; OBJECTION. VAGUE AS TO TIME. <br />09:45:13 <br />23 <br />THE WITNESS: I DON'T RECALL THE SPECIFIC TITLE. <br />24 <br />Q BY MR. RUBINER: DID YOU HAVE THE SAME J08 <br />09:45:13 <br />25 <br />47 <br />Q BY MR. RUBINER: WHEN YOU WERE AT PC <br />INVESTMENTS, DID YOU -- STRIKE THAT. <br />AT PC INVESTMENTS YOU ALSO SAID THAT THERE WAS <br />A DIFFERENCE WITH KAPLAN IN THAT YOU ACQUIRED EXISTING <br />MULTI -FAMILY UNITS; IS THAT RIGHT? <br />A CORRECT. <br />Q WHILE YOU WERE AT PC INVESTMENTS, DID <br />YOU -- STRIKE THAT. <br />HOW MANY - WHILE YOU WERE AT PC INVESTMENTS, <br />DID YOU DEVELOP ANYTHING OTHER THAN MULTI -FAMILY <br />PROJECTS? <br />MR. BISNO: OBJECTION. VAGUE AS TD TIME. <br />OBJECTION. RELEVANCE. <br />THE WITNESS: NOT THAT I RECALL. <br />Q BY MR. RUBINER: AND DID YOU DEVELOP ANY <br />MULTI -FAMILY PROJECTS IN ORANGE COUNTY? <br />MR. BISNO: DEJECTION. RELEVANCE. OBJECTION. <br />VAGUE AS TO TIME, <br />THE WITNESS: NO. <br />Q BY 9. RUBINER: DID YOU DEVELOP ANY <br />MULTI -FAMILY PROJECTS WHILE AT PC INVESTMENTS OUTSIDE OF <br />LOS ANGELES COUNTY? <br />MR. DISKO: OBJECTION, VAGUE AS TO TIME, <br />OBJECTION. RELEVANCE. <br />THE WITNESS: NOT THAT I RECALL, <br />PAGE 46 PAGE 48 <br />1 TITLE THE ENTIRE TIME BETWEEN '96 AND '98? 09:15:13 1 Q BY MR. RUBINER: DO YOU RECALL WHETHER YOU <br />09:45:13 2 MR. BISNO: OBJECTION. RELEVANCE. 2 BUILT ANY PROJECTS ''WHILE YOU WERE WORKING AT PC <br />09:45:13 3 THE WITNESS: I DON'T THINK I HAD A TITLE. 3 INVESTMENTS? <br />09:45:13 4 Q BY MR. RUBINER: OTHER THAN YOU AND MR. CHAN, 09:45:13 4 MR. BISNO: OBJECTION. RELEVANCE, OBJECTION, <br />5 DID ANYONE ELSE WORK FOR PC INVESTMENTS BETWEEN '96 AND 5 VAGUE AS TO TIME. <br />6 '98, AS FAR AS YOU KNOW? 09:45:13 6 THE WITNESS: YES. <br />D9:45:13 7 MR, BISNO: OBJECTION. RELEVANCE, OBJECTION, 09:15:13 7 Q BY MR. RUBINER: NOW MANY PROJECTS DO YOU <br />8 VAGUE AS TO TIME. 8 RECALL THAT YOU WERE INVOLVED IN THAT YOU BUILT WHILE AT <br />09:45:13 9 THE WITNESS: THERE WAS AN OFFICE STAFF THERE THAT 9 PC INVESTMENTS? <br />10 SEEMED TO DO ACCOUNTING AND OTHER MANAGEMENT ROLES. 09:45:13 10 MR. BISNO: OBJECTION, RELEVANCE. <br />09:45:13 11 Q BY MR, RUBINER: NOW, YOU STATED THAT YOU ALSO 09:45:13 11 THE WITNESS: YOUR QUESTION "BUILT' IS A FUNNY <br />12 I'IERE, WORKING FOR THE KAPLAN FAMILY YOU DID PROPERTY 12 QUESTION TO ASK A DEVELOPER. I THINK YOU SHOULD SORT OF <br />13 DEVELOPMENT. DID YOU DO THE SAME, DID YOU HAVE THE SAME 13 FINE TUNE THE QUESTION. <br />14 DUTIES CONCERNING PROPERTY DEVELOPMENT WITH PC 09:45:13 14 Q BY MR. RUBINER: WHAT IS CONFUSING ABOUT THE <br />15 INVESTMENTS? 15 QUESTION? <br />09:45:13 16 MR. BISNO: OBJECTION. VAGUE AS TO TIME. 09:45:13 16 A I DON'T, FOR THE MOST PART, IN MY CAPACITY, MY <br />17 OBJECTION. RELEVANCE. 17 CAREER, I DON'T BUILD PROJECTS. I THINK OF THE WORD <br />09:45:13 18 THE WITNESS: THERE WERE DIFFERENT NUANCES TO IT. 18 "BUILD" AS WHAT A GENERAL CONTRACTOR WOULD DO. I DON'T <br />09:15:13 19 Q BY MR. RUBINER: HOW WERE THEY DIFFERENT? 19 HAVE A GENERAL CONTRACTOR'S LICENSE, <br />09:45:13 20 MR. BISNO: OBJECTION. RELEVANCE. OBJECTION. 09:45:13 20 Q DID YOU HAVE ANY PROJECTS THAT YOU DEVELOPED <br />21 VAGUE AS TO TIME. 21 'WHERE THERE WAS NOT AN EXISTING BUILDING -- <br />09:45:13 22 THE WITNESS: THE KAPLAN FAMILY WAS CONSIDERED A 09:45:13 22 MR, BISNO: OBJECTION. <br />23 NUMBER OF THINGS BUT WAS NOT TRULY ACTIVE IN PURSUING 09:45:13 23 Q BY MR. RUBINER: -- WHILE AT PC INVESTMENTS? <br />24 NEW VENTURES WHEREAS PC WAS MORE ACTIVE, AGGRESSIVE AND 09:15:13 24 MR. BISNO: I'M SORRY. <br />25 WE ACTUALLY DID A NUMBER OF THINGS. 09:45:13 25 OBJECTION. VAGUE AND AMBIGUOUS. WHAT DO YOU <br />461 46 <br />Dalesandro vs. Ogulnick <br />Deposition of Ryan Andrew Ogulnick, Vol. 1 <br />August 13, 2012 <br />
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