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R. Leonard, C.S.R., Inc. Certified Shorthand Reporters 818.995.2449 SHEET 4 PAGE 13 PAGE 15 09:45:13 1 THE PERSON TO MY LEFT, YOUR RIGHT IS THE COURT 09:45:13 1 Q IN THE LAST YEAR, HAVE YOU DONE ANYTHING TO 2 REPORTER AND IT'S HER JOB TO TAKE DOWN EVERY WORD THAT'S 2 LOOK FOR DOCUMENTS CONCERNING MR. DALESANDRD? 3 SAID BY ANYBODY IN THE ROOM DURING THE COURSE OF THE 09:45:13 3 A NO. 4 DEPOSITION. 09:45:13 4 Q IN THE LAST YEAR, HAVE YOU DONE ANYTHING TO 09:45:13 5 DO YOU UNDERSTAND? 5 LOOK FOR DOCUMENTS CONCERNING PARALLEL? STRIKE THAT. 09:45:13 6 A I 30. 09:45:13 6 IF I USE THE PHRASE "PARALLEL' TO REFER TO 09:45:13 1 Q BECAUSE THE COURT REPORTER IS WORKING ON THIS 7 PARALLEL REAL ESTATE ADVISORS, WIL, YOU UNDERSTAND WHAT 8 SPECIAL MACHINE, IT'S IMPORTANT THAT ONLY ONE OF US B PM REFERRING TO? 9 SPEAK AT A TIME. 09:45:13 9 A YOU NEED TO REPHRASE THE QUESTION. I DON'T 09:45:13 10 DO YOU UNDERSTAND? 10 UNDERSTAND THAT QUESTION. 09:45:13 11 A I AM FAMILIAR WITH THAT PROCESS. 09:45:13 11 Q OKAY. D9;45:13 12 Q ADDITIONALLY, BECAUSE THE COURT REPORTER IS 09:45:13 12 ARE YOU FAMILIAR THAT THERE'S A PARTY IN THIS 13 USING THIS SPECIAL MACHINE, IT'S IMPORTANT THAT WE USE 13 CASE CALLED PARALLEL REAL ESTATE ADVISORS? 14 WORDS AND NOT NODS OF THE HEAD OR SHAKES OF THE 09:45:13 14 A ND. 15 SHOULDERS OR COLLOQUIAL PHRASES SUCH AS 'UM-HMM' OR 09:45:13 15 Q HAVE YOU EVER HEARD OF A COMPANY CALLED 16 'UN -HUH" OR "UH-HUH." 16 PARALLEL REAL ESTATE ADVISORS? 09:45:13 11 DO YOU UNDERSTAND? 09:45:13 17 A YES. 09:45:13 18 A I DO, 09:45:13 18 Q WHEN DID YOU FIRST HEAR OF IT? 09:45:13 19 Q IF YOU DON'T HEAR A QUESTION, ASE ME RIGHT AWAY 09:15:13 19 A SUMMER OF 2010. 20 AND I CAN REPEAT THE QUESTION OR ASK THE COURT REPORTER 09:45:13 20 Q IN WHAT CONNECTION? 21 TO REPEAT THE QUESTION. 09:45:13 21 A I WAS INTRODUCED TO THAT COMPANY AND SEAN WAS 09:45:13 22 DO YOU UNDERSTAND? 22 ONE OF THE PRINCIPALS. I'M NOT SURE IF HE WAS THE ONLY 09:45:13 23 A YES, 23 PRINCIPAL. ONE OF THE PRINCIPALS. AND HE WAS BROKERING 09:45:13 24 Q ADDITIONALLY, IF YOU DON'T HEAR A 24 CAPITAL. 25 QUESTION -- I'M SORRY -- IF YOU DON'T UNDERSTAND A 09:45:13 25 Q AND WHAT WERE YOU TOLD THE COMPANY'S NAME WAS? 13 15 PAGE 14 PAGE 16 I QUESTION, LET ME KNOW AND WE CAN FIND OUT WHATEVER IT IS 09:45:13 1 A PARALLEL. 2 ABOUT THE QUESTION YOU DON'T UNDERSTAND AND HAVE A 09:45:13 2 Q SO IF I REFER TO THE COMPANY AS PARALLEL, WILL 3 QUESTION SO THAT YOU UNDERSTAND IT. 3 YOU UNDERSTAND WHAT I'M REFERRING TO? D9:45:13 4 DO YOU UNDERSTAND? 09:45:13 4 A IN THAT CAPACITY, YES. 09:45:13 5 A YES. 09:45:13 5 Q HAVE YOU EVER LOOKED FOR DOCUMENTS CONCERNING 09:45:13 6 Q IF YOU ANSWER A QUESTION WE'LL ALL ASSUME THAT 6 PARALLEL? 3 YOU BOTH HEAD THE QUESTION AND UNDERSTOOD WHAT IT MEANT. 09:45:13 7 A NO. 09:15:13 8 DO YOU UNDERSTAND? 09:45:13 B Q DID ANYONE EVER ASK YOU TO LOOK FOR DOCUMENTS 09:15:13 9 A YES. 9 CONCERNING MR. DALESANDRO? 09:45:13 10 Q YOU UNDERSTAND THAT YOU'RE UNDER OATH? 09:15:13 10 A YES. 09:45:13 11 A YES. 09:45:13 11 Q WHO? D9:45:13 12 Q THAT MEANS THAT YOUR TESTIMONY TODAY CARRIES 09:45:13 12 MR. BISNO: OBJECTION TO THE EXTENT THAT IT CALLS 13 THE SAME WEIGHT AS IF YOU WERE TESTIFYING IN COURT 13 FOR DISCLOSURE OF ATTORNEY -CLIENT COMMUNICATION. 14 BEFORE A JUDGE AND A JURY. 09:45:13 14 THE WITNESS: IT WOULD BE ONE OF MY ATTORNEYS. 09:45:13 15 DO YOU UNDERSTAND? 09:45:13 15 MR. BISNO: I WILL INSTRUCT YOU NOT TO ANSWER A 09:45:13 16 A I DO. 16 QUESTION THAT CALLS FOR ANY REVELATION OF 09:15:13 11 Q HAVE YOU HAD ANY PROBLEMS UNDERSTANDING ANY OF 17 ATTORNEY -CLIENT COMMUNICATION. 18 MY QUESTIONS OR COMMENTS THUS EAR? 09:45:13 18 THE WITNESS: OKAY. 09:45:13 19 A NO. 09:45:13 19 MR. BISNO: TELL ME AND I WILL PUT IT ON THE 09:45:13 20 Q CAN YOU THINK OF ANY REASON YOU CAN'T PROVIDE 20 RECORD. 21 COMPLETE, ACCURATE AND TRUTHFUL TESTIMONY TODAY? 09:45:13 21 THE WITNESS: OKAY. 09:45:13 22 A NOT AT THIS TIME. 09:15:13 22 Q BY MR. RUBINER: BUT YOU NEVER LOOKED FOR 09:45:13 23 Q DID YOU DO ANYTHING TO PREPARE FOR THE 23 DOCUMENTS CONCERNING MR. DALESANDRON IS THAT CORRECT? 24 DEPOSITION TODAY? 09:45:13 24 A NO, 09:45:13 25 A NO. 09:45:13 25 MR. BISNO: ASKED AND ANSWERED. OBJECTION. 141 1 16 Dalesandro vs. Ogulnick Deposition of Ryan Andrew Ogulnick, Vol. 1 August 13, 2012