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R. Leonard, C.S.R., Inc. <br />Certified Shorthand Reporters <br />818.995.2449 <br />SHEET <br />39 PAGE 153 <br />PAGE <br />155 <br />1 <br />AND LESS THAN AN HOUR. <br />09:45:13 <br />1 <br />A TEN MONTHS AGO. <br />09:45:13 <br />2 <br />Q WHAT WAS DISCUSSED? <br />09:45:13 <br />2 <br />Q WHERE DID THE CONVERSATION TAEE PLACE? <br />09:45:13 <br />3 <br />A I DON'T RECALL. <br />09:45:13 <br />3 <br />A AT HIS HOUSE. <br />09:45:13 <br />4 <br />Q DID YOU MAKE ANY NOTES OF THE CONVERSATION? <br />09:45:13 <br />4 <br />Q WHO WAS PRESENT? <br />09:45:13 <br />5 <br />A I DID NOT, <br />09:45:13 <br />5 <br />A MY BROTHER CRAIG AND MY WIFE RACHEL, <br />09:45:13 <br />6 <br />Q DO YOU EVER MAKE ANY NOTES OF ANY OF YOUR <br />09:45:13 <br />6 <br />Q ANYONE ELSE? <br />1 <br />CONVERSATIONS WITH MR. DALESANDRO? <br />09:45:13 <br />7 <br />A NO. <br />09:15:13 <br />B <br />A IT'S NOT A HABIT OF MINE, NO. <br />09:45:13 <br />8 <br />Q HOW LONG DID THE CONVERSATION LAST? <br />09:45:13 <br />9 <br />Q WHETHER IT'S A HABIT OR NOT, DO YOU RECALL EVER <br />09:45:13 <br />9 <br />A 30 MINUTES. <br />10 <br />TAKING ANY NOTES OF ANY OF YOUR CONVERSATIONS WITH <br />09:45:13 <br />10 <br />Q WHAT WAS DISCUSSED? <br />11 <br />MR. DALESANDRO? <br />09:45:13 <br />11 <br />A THAT THERE WAS A LAWSUIT FILED, <br />D9:45:13 <br />12 <br />- MR, BISNO: VAGUE AS -- OBJECTION, VAGUE AS TD <br />09:45:13 <br />12 <br />Q ANYTHING ELSE? <br />13 <br />TIME. <br />09:45:13 <br />13 <br />A JEREMY'S PERCEPTION AND RACHEL'S PERCEPTION OF <br />D9:45:13 <br />14 <br />THE WITNESS: I DDN'T REMEMBER SPECIFICALLY TAKING <br />14 <br />SEAN, <br />15 <br />A PEN TO PAPER AND WRITING NOTES, NO, I DON'T. <br />09:45:13 <br />15 <br />Q ANY OTHER TOPICS DISCUSSED? <br />09:45:13 <br />16 <br />Q BY MR. RUBINER: AND YOU HAVE NO RECALL OF WHAT <br />09:45:13 <br />16 <br />A THE LIKELIHOOD OF DALESANDRO EXTRACTING MONEY <br />17 <br />WAS DISCUSSED DURING THE CONVERSATION; 15 THAT RIGHT? <br />17 <br />IN THE CASE. <br />09:45:13 <br />18 <br />MR. BISNO: OBJECTION. ASKED AND ANSWERED. <br />09:45:13 <br />18 <br />Q ANYTHING ELSE DISCUSSED? <br />09:45:13 <br />19 <br />THE WITNESS: I DON'T EVEN KNOW WHAT CONVERSATION <br />09:45:13 <br />19 <br />A NOT THAT I RECALL. <br />20 <br />YOU'RE TALKING ABOHT ANYMORE. <br />09:45:13 <br />20 <br />Q WHAT DID YOUR BROTHER JEREMY SAY ABOUT HIS <br />09:45:13 <br />21 <br />Q BY MR. RUBINER: AT THE GOLF COURSE, <br />21 <br />PERCEPTION OF MR. DALESANDRO? <br />09:45:13 <br />22 <br />A I'VE ALREADY TESTIFIED THAT I DON'T REMEMBER <br />09:45:13 <br />22 <br />A HE'S THE TYPE OF SALESMAN THAT HE AVOIDS <br />23 <br />THAT CONVERSATION. <br />23 <br />HIRING. HE HAS UNDER HIS GANGS TYPICALLY 100 TO 200 <br />09:45:13 <br />24 <br />Q ALL YOU RECALL IS THAT YOU HAD A MEETING THAT <br />24 <br />SALESMEN AND HE SAYS THIS TYPE OF GUY COMES ACROSS AS A <br />25 <br />WAS MORE THAN 15 MINUTES AND LESS THAN AN HOUR WITH <br />25 <br />SLICK WILLY, OVERCONFIDENT, WEARS DESIGNER SUITS, IN HIS <br />1S3 <br />155 <br />- PAGE <br />154 <br />PAGE <br />156 <br />1 <br />MR, DALESANDRO ON THE BALCONY ADJACENT TO THE BAR AT <br />1 <br />OPINION DOES NOT BODE WELL FOR INGRATIATING THE CLIENT, <br />2 <br />YOUR GOLF CLUB; IS THAT RIGHT? <br />2 <br />ALIGNING THE CLIENT WITH THE SALESMAN AND IT'S NEVER <br />09:45:13 <br />3 <br />MR. BISNO: OBJECTION. COUNSEL, YOU'RE BADGERING <br />3 <br />WORKED OUT WELL WITH HIM, AND HIS PERCEPTION WAS THAT <br />4 <br />THIS WITNESS. HE'S TESTIFIED WHAT HE RECALLS. HE'S <br />4 <br />SEAN IS THAT TYPE OF SALESMAN THAT WAS OVERSELLING. <br />5 <br />TESTIFIED WHAT HE DOESN'T RECALL. <br />09:45:13 <br />5 <br />Q DID HE SAY ANYTHING ELSE? <br />01:45:13 <br />6 <br />MR. RUBINER: ARE YOU FINISHED? <br />09:45:13 <br />6 <br />A HE ASKED ME HOW THE SYSTEM COULD WORK THIS WAY <br />D9:45:13 <br />7 <br />MR. BISNO: YES. <br />7 <br />AND HOW SOMEBODY COULD MAKE A CLAIM AGAINST A PROJECT I' <br />09:45:13 <br />8 <br />Q BY MR. RUBINER: YOU CAN ANSWER THE QUESTION, <br />8 <br />WAS DOING. <br />09:45:13 <br />9 <br />A I DO RECALL HIM AT THE CLUB ON THE PATIO. I <br />09:45:13 <br />9 <br />Q DID HE SAY ANYTHING ELSE? <br />10 <br />DON'T REMEMBER THE DATE. I DON'T REMEMBER WHAT FLAS <br />09:45:13 <br />10 <br />A THERE WAS DISCOURSE BETWEEN HIM AND RACHEL. <br />11 <br />DISCUSSED. <br />09:45:13 <br />11 <br />Q WHAT DID HE AND RACHEL HAVE DISCOURSE ABOUT? <br />09:45:13 <br />12 <br />Q HAVE YOU EVER HAD ANY DISCUSSIONS WITH YOUR <br />09:45:13 <br />12 <br />A RACHEL SAID THAI SHE HAD NEVER SEEN ME GET SO <br />13 <br />BROTHER JEREMY ABOUT ANY MEETINGS THAT YOU BAD WITH <br />13 <br />UPSET WITH SOMEBODY IN THE YEARS SHE HAD BEEN AROUND ME <br />14 <br />MR. DALESANDRO? <br />14 <br />AND SAID THAT I BAD FELT BETRAYED, I HAD RELIED ON HIS <br />09:45:13 <br />15 <br />A YES. <br />15 <br />MISREPRESENTATIONS, HIS ABILITY TO GET IBIS DONE, AND <br />09:45:13 <br />16 <br />Q DOW MANY DISCUSSIONS HAVE YOU HAD WITH YOUR <br />16 <br />RACHEL WAS VERY UPSET THAT I WAS UPSET, AND JEREMY SAID <br />11 <br />BROTHER JEREMY ABOUT MEETINGS YOU'VE HAD WITH <br />17 <br />"NEXT TIME YOU'RE DOING BUSINESS WITH A BROEER LET ME <br />18 <br />MR. DALESANDRO? <br />18 <br />INTERVIEW HIM AND I'LL MAKE SURE I THINK HE HAS AT LEAS- <br />09:45:13 <br />19 <br />A MORE THAN FIVE AND LESS THAN 20. <br />19 <br />THE SKILLS TO BE SUCCESSFUL." <br />09:45:13 <br />20 <br />Q HAVE YOU EVER DISCUSSED WITH YOUR BROTHER <br />09:45:13 <br />20 <br />THE VIDEOGRAPHER: WE HAVE ABOUT FOUR MINUTES. <br />21 <br />JEREMY WHETHER YOU HAD ANY DISCUSSIONS WITH <br />09:45:13 <br />21 <br />MR. RUBINER: RIGHT. <br />22 <br />MR. DALESANDRO AT YOUR GOLF CLUB? <br />09:45:13 <br />22 <br />WE NEED TO TAKE A BREAK WHILE SHE CHANGES <br />39:45:13 <br />23 <br />A I DON'T RECALL THAT. <br />23 <br />TAPES. <br />39:45:13 <br />24 <br />Q WHEN WAS THE LAST CONVERSATION YOU HAD WITH <br />09:45:13 <br />24 <br />THE VIDEOGRAPHER: WE'RE OFF THE RECORD 2:29 P.M. <br />25 <br />YOUR BROTHER JEREMY ABOUT MR. DALESANDRO? <br />09:45:13 <br />25 <br />(RECESS HELD). <br />159 <br />156 <br />Dalesandro vs. Ogulnick <br />Deposition of Ryan Andrew Ogulnick, Vol. 1 <br />August 13, 2012 <br />