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CORRESPONDENCE - NON-AGENDA
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City Clerk
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9/1/2020
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R. Leonard, C.S.R., Inc. <br />Certified Shorthand Reporters <br />818.995.2449 <br />SHEET <br />13 PAGE 49 <br />PAGE <br />51 <br />1 <br />MEAN BY THE WORD DID "YOU"? <br />09:45:13 <br />1 <br />THE WITNESS: THERE WAS ENTITLEMENTS, NOT <br />09:45:13 <br />2 <br />Q BY MR. RUBINER: YOU CAN ANSWER. <br />2 <br />DEVELOPMENT, <br />09:45:13 <br />3 <br />MR. DISKO: DO YOU UNDERSTAND WHAT -- <br />09:45:13 <br />3 <br />Q BY MR. RUBINER: WHEN YOU SAY THERE WERE <br />09:45:13 <br />4 <br />MR. RUBINER: COUNSEL -- <br />4 <br />ENTITLEMENTS, WHAT DOES THAT MEAN? <br />09:45:13 <br />5 <br />MR. BISND: -- COUNSEL MEANS BY THE WORD -- <br />09:45:13 <br />5 <br />A TO TAKE AN EXISTING SITE WHICH FALLS UNDER A <br />09:15:13 <br />6 <br />MR, RUBINER: COUNSEL, I OBJECT TO YOUR <br />6 <br />PARTICULAR ZONING PLOT AND HAVE A FORMAL APPLICATION <br />7 <br />INTERRUPTING THE WITNESS BEFORE BE ANSWERS THE QUESTION. <br />7 <br />WITH A JURISDICTION, A CITY, AND THAT RESULTS IN A <br />B <br />I TOLD HIM AT THE BEGINNING IF HE DOESN'T UNDERSTAND A <br />B <br />PROPERTY GETTING VESTED 4IITH CERTAIN DEVELOPMENT RIGHTS. <br />9 <br />QUESTION HE CAN ASK, HE CAN TELL ME THAT HE DOESN'T <br />09:45:13 <br />9 <br />Q AND WERE YOU PERSONALLY INVOLVED IN ANY OF <br />10 <br />UNDERSTAND IT, BUT FOR YOU TO SUGGEST REASONS WHY HE MAY <br />10 <br />THOSE ENTITLEMENTS WHILE YOU WERE WORKING FOR THE KAPLAN <br />11 <br />OR MAY NOT UNDERSTAND THE QUESTION IS HIGHLY IMPROPER. <br />11 <br />FAMILY? <br />G9:45:13 <br />12 <br />MR. BISND: COUNSEL, I DIDN'T UNDERSTAND THE <br />09:45:13 <br />12 <br />A YES. <br />13 <br />QUESTION, <br />09:45:13 <br />13 <br />Q HOW MANY? <br />09:45:13 <br />14 <br />MR. RUBINER: THAT'S IRRELEVANT WHETHER YOU <br />09:45:13 <br />14 <br />A I DON'T RECALL. <br />15 <br />UNDERSTOOD IT OR NOT. IT'S WHETHER THE WITNESS <br />09:45:13 <br />15 <br />Q MORE THAN TWO? <br />16 <br />UNDERSTOOD IT, IF HE UNDERSTANDS IT HE CAN ANSWER. IF <br />09:45:13 <br />16 <br />A I DON'T RECALL. <br />17 <br />HE DOESN'T UNDERSTAND IT HE CAN TELL ME. YOUR <br />09:45:13 <br />17 <br />Q MORE THAN TEN? <br />18 <br />UNDERSTANDING IS COMPLETELY IMMATERIAL. <br />09:45:13 <br />16 <br />A I DON'T RECALL. <br />05:45:13 <br />19 <br />MR. BISND: COUNSEL, LET'S HAVE A PROTOCOL. I'It <br />09:45:13 <br />19 <br />Q MORE THAN A HUNDRED? <br />20 <br />LET YOU FINISH YOUR RECORD, LET ME FINISH MINE. <br />09:45:13 <br />20 <br />MR. BISNO: COUNSEL, HE'S NOW ANSWERED TWICE AS TO <br />09:15:13 <br />21 <br />NOW TO ALLOW ME TO FINISH MINE, I DON'T DOUBT <br />21 <br />"MORE THAN." HE'S TESTIFIED BOTH TIMES CONSISTENTLY "I <br />22 <br />THAT MY CLIENT IS SMARTER THAN I All. I DIDN'T <br />22 <br />DON'T RECALL." THIS IS BADGERING THE WITNESS. <br />09:15:13 <br />23 <br />UNDERSTAND THE QUESTION. I WANT TO MAKE SORE HE DID, <br />09:45:13 <br />23 <br />Q BY MR. RUBINER: WAS IT MORE THAN A HUNDRED <br />24 <br />DO YOU UNDERSTAND WHAT COUNSEL MEANS WHEN HE <br />24 <br />TIMES? <br />25 <br />USES THE WORD, QUOTE, "YOU," CLOSE QUOTE? <br />09:45:13 <br />25 <br />MR. DISNO: OBJECTION. YOU'RE BADGERING THE <br />99 <br />51 <br />PAGE 50 <br />PAGE 52 <br />09:45:13 <br />1 <br />THE WITNESS: I DO NOT. <br />1 <br />WITNESS. HE'S NOW TESTIFIED TWICE HE ➢DES NOT RECALL. <br />00:45:13 <br />2 <br />MR. BISND: OBJECTION. VAGUE AND AMBIGUOUS. <br />5:13 <br />2 <br />Q BY MR. RUBINER: SO COULD YOU HAVE WORKED ON <br />09:45:13 <br />3 <br />MR. RUBINER: I'M SORRY. <br />3 <br />ENTITLEMENTS FOR THE KAPLAN FAMILY ON MORE THAN A <br />09:15:13 <br />4 <br />CAN YOU GO BACK TO THE ORIGINAL QUESTION AND <br />[09:45:13 <br />4 <br />HUNDRED SEPARATE OCCASIONS? <br />5 <br />REPEAT IT FOR ME. <br />5:13 <br />5 <br />MR. BISND: COUNSEL, YOU'RE BADGERING THE WITNESS. <br />09:45:13 <br />6 <br />(QUESTION READ), <br />6 <br />I'D ASK YOU TO MOVE ON, <br />09:45:13 <br />7 <br />MR. RUBINER: ONE SECOND. <br />7 <br />Q BY MR, RUBINER: YOU CAN ANSWER THE QUESTION. <br />09:45:13 <br />8 <br />Q DID YOU UNDERSTAND THAT QUESTION? <br />:5:13 <br />B <br />A I DON'T RECALL. <br />09:15:13 <br />9 <br />A I BELIEVE MY ATTORNEY'S COMMENT IS ACCURATE AND <br />09:45:13 <br />9 <br />Q DURING THE COURSE OF YOUR CAREER, HOW MANY <br />10 <br />I DON'T UNDERSTAND WHAT THE WORD "YOU" MEANS, IN WHAT <br />10 <br />TIMES HAVE YOU WORKED ON ENTITLEMENTS FOR AN EXISTING <br />11 <br />CAPACITY. <br />11 <br />SITE? <br />09:45:13 <br />12 <br />Q DID PC INVESTMENTS, IF I CHANGE 'YOU" TO PC <br />09:45:13 <br />12 <br />A I DON'T KNOW WHAT THE WORD "EXISTING SITE° <br />13 <br />INVESTMENTS, DO YOU UNDERSTAND THE QUESTION? <br />13 <br />MEANS. <br />09:45:13 <br />14 <br />A I DO. <br />09:45:13 <br />14 <br />Q WELL, WHEN YOU TESTIFIED -- CAN YOU REPEAT HIS <br />09:45:13 <br />15 <br />Q CAN YOU ANSWER THE QUESTION USING PC <br />15 <br />PRIOR ANSWER? <br />16 <br />INVESTMENTS TO MEAN YOU? <br />09:45:13 <br />16 <br />(ANSWER READI. <br />09:15:13 <br />17 <br />A I DON'T RECALL THERE BEING ANY SITES ACQUIRED <br />09:45:13 <br />I7 <br />Q BY MR. RUBINER: AND WHEN YOU USE THE PHRASE <br />18 <br />THAT WERE VACANT PIECES OF DIRT. I THINK THEY WERE, <br />16 <br />"EXISTING -- " CAN YOU READ THE QUESTION THAT THAT <br />19 <br />THERE WAS SOME EXISTING STRUCTURE, AN OLD LIMITED <br />19 <br />WAS -- I APOLOGIZE -- THAT THAT WAS IN RESPONSE TO. <br />20 <br />DENSITY EXISTING MULTIFAMILY. <br />09:45:13 <br />20 <br />(QUESTION READ). <br />09:45:13 <br />21 <br />Q WHILE YOU WERE AT THE KAPLAN, WITH THE KAPLAN <br />09:45:13 <br />21 <br />Q BY MR. RUBINER: WHEN YOU USED THE PHRASE <br />22 <br />FAMILY, DID THE KAPLAN FAMILY DEVELOP ANY PROJECTS FROM <br />22 <br />"EXISTING SITE" WEEK YOU WERE ANSWERING MY QUESTION <br />23 <br />DIRT? <br />23 <br />ABOUT ENTITLEMENTS, WHAT DID YOU MEAN BY EXISTING SITE? <br />09:45:13 <br />24 <br />MR, DISNO: OBJECTION. VAGUE AS TO TIME. <br />09:45:13 <br />24 <br />A I THINK THE WORD IS PROBABLY INTERCHANGEABLE <br />25 <br />OBJECTION, RELEVANCE. <br />25 <br />WITH A PARTICULAR SITE. <br />501 <br />52 <br />Dalesandro vs. Ogulnick <br />Deposition of Ryan Andrew Ogulnick, Vol. 1 <br />August 13, 2012 <br />
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