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- SHEET <br />1 <br />2 <br />4 5: 13 3 <br />15 13 <br />45:13 <br />45:13 <br />4 5: 13 <br />:45:13 <br />:15:13 <br />5 <br />6 <br />i <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 />24 <br />25 <br />R. Leonard, C.S.R., Inc. <br />Certified Shorthand Reporters <br />818.995.2449 <br />36 PAGE 141 <br />TO SEAN AND THEY DECIDED TO DO IT. CERTAINLY, MY WIFE <br />PREPARED THOSE CARDS. <br />Q DID YOU EVER TELL YOUR WIFE -- DID YOU EXPECT <br />MR. -- DID YOU EVER TELL MR. DALESANDRO NOT TO SHOW <br />THOSE CARDS TO ANYONE? <br />A I DON'T RECALL THAT. <br />Q DID YOU EVER REQUEST THAT MR. DALESANDRO RETURN <br />THE CARDS TO YOU? <br />A I DO RECALL AFTER I TERMINATED THE RELATIONSHIP <br />THAT THERE WAS SOME DIRECTION THAT YOU'RE -- YOU HAVE NO <br />AFFILIATION AND DON'T REPRESENT YOU HAVE ANY AFFILIATION <br />WITH VINEYARD. <br />Q WHY -- DID YOU EVER APPROVE OF THE PREPARATION <br />OF BUSINESS CARDS? <br />A NO. <br />Q NOW, DOES YOUR WIFE EVER TELL YOU WHY SHE WOULD <br />PREPARE BUSINESS CARDS FOR MR. DALESANDRO IDENTIFYT_NG <br />HIM AS CHIEF FINANCIAL OFFICER -- <br />MR. BISNO: OBJECTION. <br />Q BY MR. RUBINER: -- WHEN SHE WAS THE CHIEF <br />FINANCIAL OFFICER OF THE COMPANY? <br />MR. BISNO: OBJECTION. L DO NOT BELIEVE THAT IT'S <br />POSSIBLE TO ANSWER THE QUESTION AS PHRASED WITHOUT <br />REPORTING OR WITHOUT YOUR TESTIMONY INCLUDING WHAT YOU <br />HEARD FROM YOUR WIFE AND THEREFORE I WILL INSTRUCT YOU <br />PAGE <br />:13 1 <br />2 <br />13 3 <br />45:13 <br />45:13 <br />45:13 <br />45:13 <br />4 5: 13 <br />45:13 <br />45:13 <br />:15 13 <br />4 <br />5 <br />6 <br />7 <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 />143 <br />Q YOU SAID YOU SPOKE WITH YOUR BROTHERS; IS THAT <br />CORRECT? <br />A THAT I SAID. <br />Q OKAY. <br />WHICH BROTHERS DID YOU SPEAK WITH? <br />A JEREMY, CRAIG. <br />Q WAS IT ONE CONVERSATION OR SEPARATE <br />CONVERSATIONS? <br />A I THINK THERE WERE A COUPLE. <br />Q WERE BOTH JEREMY AND CRAIG PRESENT FOR <br />BOTH <br />CONVERSATIONS? <br />A INDIVIDUALLY, SEPARATE. <br />Q WHEN WAS YOUR FIRST CONVERSATION WITH JEREMY <br />WHERE YOU DISCUSSED MR. DALESANDRO BEING CFD OF <br />VINEYARDS? <br />A I NEVER āž¢ISCUSSED HE WAS CFO, HE WOULD <br />ASK ME <br />ABOUT A BUSINESS CARD. I DISCUSSED WITH HIM WHY <br />THE <br />BUSINESS CARD CAME ABOUT, <br />Q WHEN DID YOU HAVE A CONVERSATION WITH <br />MR. JEREMY OGULNICK ABOUT A BUSINESS CARD? <br />A IT WOULD HAVE BEEN, I BELIEVE, JANUARY, <br />2010. <br />EXCUSE ME. '11, <br />Q WHERE DID THE CONVERSATION TAKE PLACE? <br />A AT HIS HOME. <br />Q WHO WAS PRESENT? <br />PAGE 142 <br />PAGE 144 <br />- <br />NOT TO ANSWER THE QUESTION AS PHRASED. <br />09:45:13 <br />1 <br />A MY WIFE RACHEL. <br />09:45:13 <br />2 <br />THE WITNESS: CAN YOU RESTATE THE QUESTION? <br />09:45:13 <br />2 <br />Q ANYONE ELSE? <br />09:15:13 <br />3 <br />Q BY MR. RUBINER: DID ANYONE EVER <br />09:45:13 <br />3 <br />A I DON'T THINK 30. <br />4 <br />QUESTION -- STRIKE THAT. <br />09:45:13 <br />4 <br />Q WHERE AT YOUR HOME DID THE CONVERSATION TARE <br />09:15:13 <br />5 <br />WHEN YOU FOUND OUT THAT MR. DALESANDRO HAD <br />5 <br />PLACE? <br />6 <br />BUSINESS CARDS THAT SAID HE WAS CHIEF FINANCIAL OFFICER, <br />09:45:13 <br />6 <br />A I SAID, AT HIS HOME, <br />7 <br />DID YOU TELL HIM NOT TO DISTRIBUTE THEM TO ANYONE? <br />09:45:13 <br />7 <br />Q WHERE AT HIS HOME DID THE CONVERSATION TAKE <br />09:45:13 <br />8 <br />A I DON'T RECALL. <br />8 <br />PLACE? <br />09:45:13 <br />9 <br />Q DID YOU RECALL EVER TELLING ANYONE THAT <br />09:45:13 <br />9 <br />A LIVING RODM. <br />10 <br />MR. DALESANDRO WAS NOT THE CHIEF FINANCIAL OFFICER OF <br />09:15:13 <br />10 <br />Q HOW LONG DID THE CONVERSATION LAST? <br />11 <br />VINEYARDS? <br />09:45:13 <br />11 <br />A 30 MINUTES. <br />09:45:13 <br />12 <br />MR. BISNO: OBJECTION TO THE EXTENT -- PARDON ME, <br />09:45:13 <br />12 <br />Q WBAT TOPICS WERE DISCUSSED? <br />13 <br />NO. I WITHDRAW TEE OBJECTION. <br />09:45:13 <br />13 <br />A SEAN'S MISREPRESENTATIONS THAT HE COULD <br />09:15:13 <br />14 <br />THE WITNESS: YES, <br />14 <br />ACTUALLY GET CAPITAL FOR A DEAL, ANY DEAL AND HOW I HAD <br />09:15:13 <br />15 <br />Q BY MR, RUBINER: WHO? <br />15 <br />FELT IN A WAY BETRAYED THAT HE CAME ACROSS TO PIE IN SUCH <br />09:15:13 <br />16 <br />A MY ATTORNEYS, MY WIFE, MY FAMILY, FRIENDS. <br />16 <br />A WAY THAT HE WAS A PRO, HE WOULD SUCCEED, AND THE <br />09:45:13 <br />17 <br />MR. BISNO: I SHOULD HAVE ASSERTED THE OBJECTION. <br />11 <br />ACTUAL RESULTS WERE HORRIFIC FOR ME AND MY COMPANY. NOT <br />09:45:13 <br />18 <br />Q BY MR, RUBINER: WHO IN YOUR FAMILY DID YOU <br />1B <br />ONLY HAD HE FAILED ON ROYAL CANYON, HE FAILED ON IRE <br />19 <br />TELL THAT MR, DALESANDRO WAS NOT THE CHIEF FINANCIAL <br />19 <br />DESERT. NOW I HAD LENT HIM $32,000 AND HE WAS FAILING. <br />20 <br />OFFICER? <br />20 <br />I HAD DISCUSSED THIS WITH MY BROTHER BECAUSE <br />09:15:13 <br />21 <br />A MY BROTHER -- BROTHERS AND 14Y WIFE. <br />21 <br />HE'S AN EXECUTIVE WITH RICO AND HE'S, I THINK HE'S VP OF <br />09:45:13 <br />22 <br />Q WHEN DID YOU SPEAK WITH YOUR BROTHER ABOUT <br />22 <br />SALES, AND I SAID WHAT CAN I GIVE THIS GUY TO MAKE HIM <br />23 <br />MR. DALESANDRO BEING CHIEF FINANCIAL OFFICER OF <br />23 <br />BETTER AT WHAT BE'S DOING, SOMETHING THAT SEAN AND I <br />24 <br />VINEYARDS? <br />24 <br />DISCUSSED AD NAUSEAM, AND HE SAID 'WELL, MAYBE IT'S THE <br />09:45:13 <br />25 <br />A IT'S NOT WHAT I SAID, <br />25 <br />CAPACITY.' <br />,421 <br />144 <br />Dalesandro vs. Ogulnick <br />Deposition of Ryan Andrew Ogulnick, Vol. I <br />August 13, 2012 <br />