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R. Leonard, C.S.R., Inc.
<br />Certified Shorthand Reporters
<br />818.995.2449
<br />SHEET
<br />14 PAGE 53
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<br />Q AND WHEN YOU SAY 'PARTICULAR SITS," WHAT DO YOU
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<br />THE NEED TO CHANGE THE UNDERLYING ZONING, WHETHER IT WAS
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<br />MEAN BY THAT?
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<br />DISCRETIONARY IN NATURE OR NOT DISCRETIONARY IN NATURE,
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<br />A ANY PARTICULAR SITE. JUST A SITE, IN GENERAL.
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<br />TYPICALLY HIRE CONSULTANTS TO HELP US IN THAT
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<br />Q SO DOES THAT MEAN THE SITE WHERE IT COULD BE
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<br />DETERMINATION, WHETHER IT WAS A LAND USE ATTORNEY, CIVIL
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<br />BOTH A BUILDING OR DIRT ON A GIVEN SITE IN YOUR ANSWER?
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<br />ENGINEER, LAND PLANNER OR ARCHITECT. AND WE WOULD THEN
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<br />A CORRECT.
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<br />MAKE A DETERMINATION IF THE ECONOMICS AND THE UNDERLYING
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<br />Q AND IN YOUR CAREER, HOW MANY TIMES HAVE YOU
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<br />ENTITLEMENT RISK MADE SENSE TO ACQUIRE THE SITE.
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<br />WORKED ON ENTITLEMENTS FOR A PARTICULAR SITE?
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<br />Q AND BETWEEN 1996 AND 1958 WHEN YOU WORKED
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<br />MR. BISNO: OBJECTION. VAGUE AND AMBIGUOUS.
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<br />FOR PC INVESTMENTS, DID YOU HAVE THE SAME
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<br />DO YOU UNDERSTAND THE WORD 'WORKED ON' AND THE
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<br />RESPONSIBILITIES --
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<br />CONTEXT IN WHICH IT IS MEANT BY COUNSEL?
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<br />MR, BISNO: OBJECTION.
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<br />MR. RUBINER: COUNSEL, I OBJECT TO YOUR SPEAKING
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<br />MR. ROSINED: -- AS FAR AS ENTITLEMENTS GO?
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<br />OBJECTIONS. IF YOU HAVE A LEGAL OBJECTION I REQUEST
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<br />MR. BISNO: I'7•f SORRY. I INTERRUPTED YOU.
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<br />THAT YOU MARE THE LEGAL OBJECTION BUT NOT SUGGEST IN
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<br />OBJECTION. RELEVANCE.
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<br />YOUR OBJECTION WHAT BASIS FOR THE OBJECTION MAY BE,
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<br />MR, RUBINER: DID YOU GET THE QUESTION?
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<br />WHAT, IF YOU CAN -- IF YOUR OBJECTION IS VAGUE AND
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<br />THE REPORTER: YES.
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<br />AMBIGUOUS, I REQUEST YOU MAKE A VAGUE AND AMBIGUOUS
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<br />THE WITNESS: I THINK THE RELATIONSHIP PROBABLY
<br />1B
<br />OBJECTION AND LET THE WITNESS, IF HE DETERMINES IT TO BE
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<br />CHANGED FROM THE INCEPTION WHEREIN WE WOULD GO OUT AND
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<br />VAGUE AND AMBIGUOUS, DO SO ON HIS OWN,
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<br />ACQUIRE SITES WHERE I WAS INITIALLY JUST AN EMPLOYEE AND
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<br />Q CAN YOU ANSWER THE QUESTION?
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<br />WHERE I BECAME A PRINCIPAL OR JOINT VENTURE PARTNER.
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<br />A I WOULD SAY MORE THAN 15, LESS THAN 50•
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<br />Q BY MR. REFINER: AND HOW DID YOUR
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<br />Q AND HOW MANY -- STRIKE THAT,
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<br />RESPONSIBILITIES CHANGE BETWEEN BEING AN EMPLOYEE AND
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<br />DID YOU WORK ON ENTITLEMENTS FOR ANY PARTICULAR
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<br />BEING A PRINCIPAL?
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<br />SITES WHILE YOU WORKED FOR THE KAPLAN FAMILY?
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<br />MR. BISNO: OBJECTION. RELEVANCE.
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<br />MR, BISNO: OBJECTION. RELEVANCE. OBJECTION,
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<br />THE WITNESS: JUST IN THE CAPACITY THAT ONCE THE
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<br />5'
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<br />VAGUE AS TO TIME.
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<br />SITE WAS ACQUIRED THERE WERE VOTING RIGHTS VESTED TO ME
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<br />THE WITNESS: YES,
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<br />AS PART OF THE MANAGEMENT TEAM,
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<br />0 BY MR. RUBINER: HOW MANY?
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<br />Q BY MR. RUBINER: DO YOU RECALL HOW MANY SITES
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<br />A I DON'T RECALL SPECIFICALLY. IF YOU WANT
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<br />YOU HAD A PRINCIPAL RELATIONSHIP WITH AS IT RELATES TO
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<br />SPECIFIC THERE WAS A SITE ON NATIONAL IN PALMS, THERE
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<br />PC INVESTMENTS BETWEEN 1996 AND 1998?
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<br />WAS A SITE IN MAR VISTA ON AVON WAY AND THERE WAS
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<br />MR. HISNO: OBJECTION. RELEVANCE. OBJECTION.
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<br />ANOTHER SITE IN I'IEST LA ON NEBRASKA, THERE WERE MORE.
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<br />RIGHT TO PRIVACY, IF WE CONTINUE ON THIS ROAD I WILL
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<br />THOSE ARE THE THREE THAT JUMP OUT AT ME AT THE M011ENT.
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<br />HAVE TO INTERPOSE MORE OBJECTIONS AND INSTRUCT MY CLIENT
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<br />Q IN REGARDS TO THE THREE SITES YOU IDENTIFIED,
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<br />NOT TO ANSWER.
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<br />WERE YOUR RESPONSIBILITIES THE 21E FOR EACH SITE?
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<br />THE WITNESS: I BELIEVE THERE WERE THREE TO FOUR,
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<br />MR. BISNO: OBJECTION. RELEVANCE.
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<br />OFF THE TOP OF MY HEAD. 156D PURDUE IN WEST LA, ANOTHER
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<br />THE WITNESS: I THINK THEY WERE.
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<br />ADDRESS ON PURDUE AND A SITE IN MAR VISTA ON AERIAL WAY.
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<br />Q BY MR. RUBINER: AND WHAT WERE YOUR
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<br />Q BY MR. RUBINER: NOW, YOU SAID THAT YOU STOPPED
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<br />RESPONSIBILITIES?
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<br />WORKING WITH PC INVESTMENTS IN 1998, APPROXIMATELY; IS
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<br />A AS I TESTIFIED PREVIOUSLY -- COULD 1 SUGGEST,
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<br />THAT RIGHT?
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<br />JOHN, THAT YOU, IF YOU COULD KEEP ME IN THAT TIME FRA12
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<br />MR. BISMO: OBJECTION. RELEVANCE,
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<br />IT WOULD BE PROBABLY BETTER FOR MY MEMORY THAN JUMPING
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<br />THE WITNESS: LIKE I SAID BEFORE, IT COULD HAVE
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<br />BACK AND FORTH. IF YOU WANT TO TALK ABOUT 2005 TO 2007,
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<br />BEEN '99.
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<br />FOR INSTANCE, TO STAY THERE I THINE WOULD BE BETTER FOR
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<br />Q BY MR, RUBINER: SO APPROXIMATELY 199B OR 1999
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<br />MY MEMORY.
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<br />YOU STOPPED WORKING WITH PC INVESTMENTS; IS THAT RIGHT?
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<br />MY RECOLLECTION WAS THAT EITHER I WOULD FIND A
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<br />A I THINK THAT'S RIGHT, YEAH.
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<br />SITE OR BEN KAPLAN WOULD FIND A SITE. WE WOULD
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<br />Q WHY DID YOU STOP WORKING WITH PC INVESTMENTS?
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<br />UNDERWRITE THE SITE FOR FUTURE DEVELOPMENT PLAY, WE
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<br />MR. BISNO: OBJECTION. RELEVANCE.
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<br />WOULD UNDERWRITE THE DIFFICULTIES OF ENTITLING THE SITE,
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<br />THE WITNESS: ON THE SITES WE HAD ACQUIRED, MY
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<br />SPECIFICALLY WHAT'S THE UNDERLYING ZONING FOLLOWED BY
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<br />RECOLLECTION WAS THAT CHAN DECIDED THAT ON ONE SITE WE
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<br />Dalesandro vs. Ogulnick
<br />Deposition of Ryan Andrew Ogulnick, Vol. 1
<br />August 13, 2012
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