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R. Leonard, C.S.R., Inc. Certified Shorthand Reporters 818.995.2449 SHEET 5 PAGE 17 PAGE 19 09:45:13 1 Q BY MR, RUBINER: DID YOU EVER -- WHAT TYPES 1 DEVELOPMENT CORPORATION? 2 OF -- WELL, DID YOU EVER HAVE A FILE OF DOCUMENTS 09:45:13 2 MR. BISNO: OBJECTION. MISSTATES PREVIOUS 3 CONCERNING MR. DALESANDRD? 3 TESTIMONY. D9:45:13 4 A NOT ME PERSONALLY. 09:45:13 4 Q BY MR. RUBINER: DID YOU SAY THAT SHE WAS CFO 09:45:13 5 Q DID YOU EVER ASK ANYBODY AT ONE OF YOUR 5 OF VINEYARDS DEVELOPMENT CORPORATION? 6 COMPANIES TO RIAINTAIN DOCUMENTS CONCERNING MR. 09:45:13 6 A I DID. EXCEPT YOU SAID CEO WHEN YOU ASKED THE 7 DALESANDRD? 7 QUESTION. 09:45:13 8 MR. BISNO: OBJECTION TO THE EXTENT THAT IT CALLS 09:45:13 8 Q BY MR. RUBINER: WHEN DID MISS OGULNICK BECOME 9 FOR THE DISCLOSURE OF ATTORNEY -CLIENT COMMUNICATION. 9 CFO OF -- 09:45:13 10 TO THE EXTENT YOU CAN ANSWER THAT QUESTION 09:45:13 10 MR. BISNO: EXCUSE ME. AGAIN, MR. SCHOTTENSTEIN IS 11 WITHOUT DISCLOSING ATTORNEY -CLIENT COMMUNICATION, YOU'RE 11 DISRUPTING THIS DEPOSITION BY GESTURING TO 12 FREE TO CO SO. 12 MR. DALESANDRD. I'M GOING TO ASK THIS TIME AND ONLY ONE D9:45:13 13 THE WITNESS: I DON'T BELIEVE THERE WAS EVER ANY 13 MORE TIME IF MR. SCHOTTENSTEIN OR MR. LEVINE PERSISTS IN 14 HARD COPIES OR ACTUALLY PIECES OF PAPER BUT LIKELY 14 DOING THAT WE WILL TERMINATE THIS DEPOSITION. 15 SOMEBODY WHO WORKS FOR ME CREATED AN E-MAIL FILE OR A 09:45:13 15 MR. RUBINER: I DON'T BELIEVE THAT HIM, THAT 16 WORD FILE, WHATEVER. A DESK TOP FILE. 16 ANYBODY PASSING NOTES OR GESTURING TO EACH OTHER IS 09:45:13 17 Q BY MR. RUBINER: WHEN YOU SAY LIKELY SOMEONE 17 DISRUPTING YOUR WITNESS OR ANYTHING THAT WOULD BE 16 WHO WORKS FOR YOU, ARE YOU AWARE OF SOMEONE WHO WORKS 16 DIFFERENT THAN WHAT EXISTS IN A TRIAL WHERE PEOPLE ARE 19 FOR YOU ACTUALLY DOING THAT? 19 ALLOWED TO WRITE. I'M GOING TO HAKE COMMENTS AND ASK 09:45:13 20 A YES. 20 QUESTIONS OF MY CLIENT THAT IS NOT DISRUPTING THE D9:45:13 21 Q AND WHO IS THE PERSON THAT WORKED FOR YOU THAT 21 DEPOSITION, THEY'VE NOT INTERRUPTED ANYTHING, THEY'VE 22 DID THAT? 22 NOT SAID ANYTHING, THEY DIDN'T GESTURE TOWARDS YOUR 09:45:13 23 A RACHEL. 23 CLIENT. YOU CAN MAKE ALL THE STATEMENTS YOU WANT BUT 09:45:13 24 Q THAT'S RACHEL OGULNICK? 24 YOU'RE INCORRECT AS TO WHAT IS GOING ON IN THIS ROOM 09:45:13 25 A CORRECT. 25 (DISCUSSION HELD OFF THE RECORD). 17 9 PAGE 16 PAGE 20 09:45:13 1 Q DID YOU EVER HAVE ANY DISCUSSIONS WITH MISS 09:45:13 1 Q BY MR. RUBINER: WHEN DID MISS OGULNICK BECOME 2 OGULNICK ABOUT CREATING A FILE OF DOCUMENTS CONCERNING 2 CFO OF VINEYARDS DEVELOPMENT CORPORATION? 3 MR. DALESANDRD? 09:45:13 3 A 2009. 09:45:13 4 MR. BISNO: OBJECTION TO THE EXTENT THAT IT CALLS 09:45:13 4 Q WAS MISS OGULNICK -- WHAT COMPANY -- .AS OF S FOR SPOUSAL COMMUNICATIOI4. S 2009, WHAT COMPAVIEE DID YOU HAVE AN OWNERSHIP INTEREST 09:45:13 6 TO THE EXTENT YOU CANNOT ANSWER THAT QUESTION 6 IN? 7 WITHOUT REVEALING SPOUSAL COMMUNICATION, I WILL DIRECT 09:45:13 7 MR. BISNO: OBJECTION. RELEVANCE, OBJECTION. B YOU NOT TO ANSWER THAT QUESTION. B RIGHT TO PRIVACY. 09:45:13 9 THE WITNESS: CAN YOU REPEAT THE QUESTION? 09:15:13 9 I'LL INSTRUCT YOU NOT TO ANSWER THE QUESTION AS 09:45:13 10 MR. RUBINER: CAN YOU REPEAT THE QUESTION. 10 PHRASED. 09:45:13 li )QUESTION READ), 09:45:13 11 Q BY MR. RUBINER: WHEN WAS VINEYARDS DEVELOPMENT 09:15:13 12 MR. BIDED: AGAIN, I WILL REFRESH YOUR 12 CORPORATION CREATED? 13 RECOLLECTION, YOUR MEMORY. TO THE EXTENT YOU MUST 09:45:13 13 A 2007. 14 REVEAL SPOUSAL COMMUNICATION TO ANSWER THAT QUESTION, I 09:45;13 14 Q AND WHO WAS THE CFO OF VINEYARDS DEVELOPMENT 15 AM DIRECTING YOU NOT TO ANSWER. 15 CORPORATION IN 2007? 09:45:13 16 THE WITNESS: I WILL NOT ANSWER, 09:45:13 16 MR. BISNO: OBJECTION. RELEVANCE. D9:45:13 17 Q BY MR. RUBINER: SO YOU'RE NOT ANSWERING BASED 09:15:13 17 YOU MAY ANSWER. 18 ON YOUR COUNSEL'S INSTRUCTION; IS THAT RIGHT? 09:45:13 18 THE WITNESS: TT WAS JEREMY OGULNICK, MY BROTHER. 09:45:13 19 A CORRECT. 09:45:13 19 Q BY MR. RUBINER: WHEN DID MR. OGULNICK STOP 09:45:13 20 Q WHAT'S MISS OGULNICK'S POSITION WITH YOUR 20 BEING CFO OF VINEYARDS DEVELOPMENT CORPORATION? 21 COMPANY? 09:45:13 21 MR. BISNO: OBJECTION. RELEVANCE. 09:45:13 22 A SHE'S CFO. SHE IS VP IN CHARGE OF DESIGN. 09:45:13 22 THE WITNESS: WHEN WE CHANGED THE FILING WITH THE 09:45:13 23 Q WHAT COMPANY IS SHE CFO OF? 23 SECRETARY OF STATE, STATEMENT OF INFORMATION, AS I 09:45:13 2 A VINEYARDS DEVELOPMENT CORPORATION. 24 STATED BEFORE, IT WOULD BE IN 2009. 09:45:13 25 Q WHEN DID SHE BECOME CEO OF VINEYARDS 09:15:13 25 Q BY MR. RUBINER: AND THAT'S WHEN MISS OGULNICK 181 20 Dalesandro vs. Ogulnick Deposition of Ryan Andrew Ogulnick, Vol. 1 August 13, 2012