Professional Documents
Culture Documents
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STRIKE. MS. MACCARLEY: DO WITH IT. CASHED? MR. CASTANEDA: MS. MACCARLEY: DON'T MIND IT. THE COURT: I WILL ALLOW IT SUBJECT TO A MOTION HERE'S THE CHECK. AND-ALL RIGHT. THIS HAS NOTHING TO
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TO STRIKE IF MR. CASTANEDA -MS. MACCARLEY: TO MY CLIENT. THE COURT: OTHER CHECKS. YES. HE CAN'T TESTIFY ABOUT ANY ONLY THE CHECK THAT WAS PAYABLE
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I DON'T KNOW THAT HE GOT THIS CHECK OR ASK HIM ABOUT THE CHECK YOU SAY
OKAY.
SHOW HIM SO HE KNOWS WHAT WE ARE TALKING ABOUT. THE COURT: IDENTIFICATION. DO YOU RECOGNIZE THAT DOCUMENT? THE WITNESS: NEVER SEEN IT BEFORE. I RECOGNIZE IT AS A CHECK( BUT I LET'S MARK THIS AS DEFENDANT'S A FOR
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THE COURT:
IS
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THE WITNESS: THE COURT: THE WITNESS: THE COURT: THE WITNESS: THE COURT: THE WITNESS: BIRTHDAY. MR. CASTANEDA: QUESTIONING? THE COURT:
MY NAME IS ON THE CHECK. FOR HOW MUCH MONEY IS IT FOR? LOOKS LIKE $200. $200. CORRECT. WHAT'S THE DATE OF THAT CHECK? MARCH 1ST '06, WHICH IS MY
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PLAUSIBLE.
THE WITNESS:
YOU DON'T RECALL AT THIS POINT? NOT OFF THE TOP OF MY HEAD. GO AHEAD, MR. CASTANEDA.
SELL THE HOUSE, AND I WOULD LIKE TO KNOW AGAIN HOW IS IT YOU SAID THAT YOU CONTACTED ME BY PHONE? WHAT EXACTLY WAS IT THAT TRANSPIRED DURING THAT CONVERSATION? A Q THERE WAS NO CONVERSATION. WELL, YOU SAID -I TRIED TO CONTACT YOU. NO ONE PICKED UP. I
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11~!\LLED 2
TIMES
AND
I LEFT
TO
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CONTACT
Q
PROCEED
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WAIT A MINUTE.
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HOUSE.
GIVE THAT
TO YOU TO SUGGEST
IT UP TO MY ATTORNEY
THAT
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OKAY.
A
Q
I RESIDE WHAT
IS THE ADDRESS?
A
Q
174017. HOW DID YOU PURCHASE I DID NOT PURCHASE THAT HOME?
A
Q
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OBJECTION. BECAUSE
DOWN
PAYMENT
FOR THAT
NOW.
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THE COURT:
MR. CASTANEDA:
I AM TRYING
THAT
THE WITNESS
MISREPRESENTED
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CONTACTED
ME TO DO THAT.
I AM TALKING
IS A DIFFERENT
UP IN LOS OSOS.
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COURT HOUSE
IS GOING
TO SUSTAIN
BY MR. CASTANEDA:
SMOKE
POT IN FRONT
OF YOUR
GRANDMA?
OBJECTION.
THE OBJECTION
REALLY
DOESN'T
TO GO ANYTHING
HE DID.
WOULD.INFER
FROM
MR. CASTANEDA:
YOUR HONOR,
AND ABOUT
THE WITNESS
HE CONTACTED
TO SELL THE HOUSE. Q WENT THAT LET ME ASK YOU SOMETHING: OFFICE? UNDER DO YOU KNOW WHEN WHAT EXACTLY OF ALL, WAS IT WITH YOU
THE PHONECALL,
FIRST
TO MEET
MR. REYES? A 1-MS. MACCARLEY: OBJECTION. KNOWS, ASSUMES THAT'S FACTS FINE. NOT IN
EVIDENCE.
BUT
IF THE WITNESS
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THE COURT: SOMEBODY TELL ME WHO MR. REYES HE HE REYES? A NOTARY. DO YOU YES. MY TAXES, IS DOES NOTARY? MS .'MACCARLEY: YES. A KNOW MR. DOES HE IS TAXES? YOUR
IS.
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ARTURO.
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DO YOU KNOW?
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Q
COMPLETELY DIFFERENT PERSON THAN THE ONE THAT THE COURT: ALL THAT. YOU'RE GOING TO HAVE TO TESTIFY ON
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STAND AND TELL ME IT'S NOT EVIDENCE FROM COUNSEL. UNTIL YOU ARE ON THE WITNESS STAND. BY MR. CASTANEDA: Q
AND CHRISTINA AND GONZALO TO THE OFFICES MR. REYES? MS. MACCARLEY: NOT IN EVIDENCE. THE COURT: LET'S BACK UP A LITTLE BIT. AGAIN, OBJECTION. ASSUMES FACTS
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DO YOU HAVE THAT EXHIBIT SIX IN FRONT OF YOU, SIR? THE GRANT DEED? THE WITNESS: THE COURT: YES. WHAT I THINK MR. JOSE CASTANEDA
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WANTS TO KNOW IS DID YOU ACCOMPANY EVELYN FELICITAS TO MR. REYES' OFFICE FOR THE EXECUTION OF THIS DEED? THE WITNESS: THE COURT: THE WITNESS: CORRECT. YOU ALL WENT TOGETHER? YES.
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 HAVE GIVEN
NEXT
QUESTION.
DATE
THERE MRS.
IS A POWER CASTANEDA,
BY MY MOTHER
HAS AS WELL. MS. MACCARLEY: THE COURT: OBJECTION. THE POWER IT WAS RELEVANCE. OF ATTORNEY ISSUED SHOW?
WHAT'S
THAT
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-- IT WAS SPOKE
OF THEM
IN ENGLISH.
MY MOTHER
MR. CASTANEDA:
OF EXECUTED
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OF THE
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BY MR. CASTANEDA:
THERE
MEI
IS A POWER
OF ATTORNEY
WHICH
STATE
YOUR
QUESTION
AGAIN.
THERE
IS TOO MANY
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1 2 3 4 S 6 7 8 9 10 11 12 MR. REYES?
THE COURT:
THAT WAS -- GAVE THE POWER OVER YOUR MOTHER-IN-LAW'S AFFAIRS TO YOU AND YOUR WIFE EXECUTED? MR. CASTANEDA: GRANDMOTHER. THAT'S MY SISTER. SORRY. PREPARED BY ANOTHER
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OBJECTION.
POWER OF ATTORNEY. THE COURT: SUSTAINED. DID YOU EVER SIGN A POWER OF ATTORNEY FOR YOUR GRANDMOTHER? THE WITNESS: I DO NOT BELIEVE I DID. ONLY LET'S BACKS IT UP. OBJECTION
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THING I DID WAS SIGN WAS THE HOUSE. MR. CASTANEDA: THE COURT: MAY I TAKE A MOMENT? I MIGHT --
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MR ._J;,ASTANEDA: IF I MAY. THE COURT: SHOW IT TO THE ATTORNEY FIRST. THIS IS MY MOTHER'S PHONE
IT IS IRRELEVANT.
JUST COPIES
COPIES OF WHAT? SOME KIND OF PHONE RECORDS. CELLPHONE RECORDS. CELLPHONE RECORDS. THERE IS NO
MR. CASTANEDA: NUMBER. MS. MACCARLEY: THE COURT: GRANDMOTHER? MS. MACCARLEY:
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J
COMPLETELY IRRELEVANT.
RIGHT.
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HAVE KNOWN FOR SEVERAL YEARS, AND I DO NOT KNOW. THE COURT: THE PROBLEM IS HE CAN'T LAY A
FOUNDATION FOR THE RECORDS FROM THE PHONE COMPANY, WHATEVER. MR. CASTANEDA: I UNDERSTAND THAT, YOUR HONOR.
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BUT THAT THE PHONE CALL WAS MADE SWEDEN SHOULD SHOW HERE IF MY MOTHER MADE PHONECALLS TO SWEDEN. IT IF MY MOTHER
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MAY HAVE CALLED LOS OSOS IN SAN LUIS OBISPO I Iu8.M JUST TRYING TO PROVE THAT MY MOTHER CONTACTED HIM, YOU KNOW, REGARDING RETURNING THE TITLE OF THE HOUSE AND THAT SHE DID NOT INTEND -- ACTUALLY THE COURT: THINGS. THAT WOULDN'T SHOW ME ANY OF THOSE
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EITHER TO OR FROM THAT LOCATION TO A NUMBER IN LOS OSOS. MR. CASTANEDA: THE COURT: THAT'S FINE.
MR. CASTANEDA: THE COURT: THE WITNESS: THE COURT: THE WITNESS: SISTER. THE COURT: THE WITNESS:
DID YOUR GRANDMOTHER CALL YOU? HERE IS CELLPHONE. CALIFORNIA TO LOS OSOS? SHE CALLED ME OCCASIONALLY, MY
HOW OFTEN WOULD SHE CALL YOU? IT WOULD DEPEND ON VARIOUS THINGS;
HOW WELL SHE WAS DOING, IF SHE WAS ABLE TO TALK, IF SHE WAS ALLOWED TO TALK. I WOULD SAY WE TRIED KEEPING IN
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THAT THE PLAINTIFF, JUST LIKE MRS. RAMIREZ, DID NOT VISIT MRS. CASTANEDA SINCE -- FOR A COUPLE OF YEARS THE LAST YEARS OF HER LIFE.
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WILL SHOW THAT PRIOR TO DISAPPEARING HER $70,000 AND THEY ALREADY OBVIOUSLY SIGNING THIS QUIET TITLE TO THEM. THE
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WAS
AND FOR THE RECORD, THAT MRS. MACCARLEY OF RECORD, HER. THE YET SHE
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-- STATE
SUSANA
CASTANEDA'S
ATTORNEY
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TWO PEOPLE
TO QUESTION
WE ARE GETTING
WAY OUTSIDE
RECORD.
I HAVEN'T FACTS.
ON ANY OF THESE
FACTS
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OR SUPPOSED
COUNTS
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THE COURT: --
AM SORRY.
KNOW WHAT
I AM NOT
--
HE DIDN'T
SHOW UP FOR DAY OF TRIAL. GIVE YOU ANY YOU ARE OR GOING
THE COURT.
WE CAN'T
I SUSPECT
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TO TAKE
MR. COUNTS. BUT, AT ANY RATE, THE PHONECALL, PHONECALLS THE GENTLEMAN THE ISSUE YOU HAD ABOUT IS A NUMBER OF
SAID THERE
THESE
PHONECALLS
ARE TO HIM, AND IS ONE OR THE NUMBER ME. -- YOU ARE ASKING A
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HE APPARENTLY
CONTACTED
AND
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GRllliDMOTHER.
MS. MACCARLEY: BASED ON THE RELEVANCE. THE COURT: GOING TO BE. MS. MACCARLEY: MR. CASTANEDA:
IS
EXACTLY. IT IS RELEVANT
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THE COURT:
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ON THERE? OF.
THE WITNESS: DO HOW MANY? COURT: YOU RECOGNIZE THE NUMBERS LISTED SHOW HIM THE NUMBER YOU WANT HIM TO BE AWARE
MR. CASTANEDA:
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OBISPO BUSINESS, SO IS THAT YOUR NUMBER, THE 550? Q A WHAT? FIVE? THAT IS NOT MY MOTHER. 528-1480 IS
550-7656.
NOT MY MOM. Q A Q WHAT ABOUT THIS? 21908 IS NOT MY NUMBER AS WELL. THERE IS A COUPLE NUMBERS? 8320, THAT IS NOT MY NUMBER.
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THE CASTANEDA: ABOUT THIS ONE? MR. COURT: WHAT 528-1980, THAT IS NOT MY MOTHER. AGAIN, EIGHT, ZERO -- THE 549-3720, THAT IS NOT MY MOTHER. THE WITNESS: 428-1980 IS NOT MY RECORD. THE OBJECTION TO THE DOCUMENT WILL
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THE COURT:
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MS. MACCARLEY: 2 3
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THE COURT:
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CASTANEDA:
PHONECALLS
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BY MR. CASTANEDA
Q
THE NEXT
QUESTION
IS:
YOU STATED
ON THE
RECORD YOU I
YOU STATED
YOU CONTACTED
YOUR
GRANDMA.
I AM SHOWING BUT
-- I AM SORRY STARTS
THE DATE
ON 11/14/07
11/29. YOUR
MONTH, DYING?
OBJECTION.
RELEVANCE. ABOUT?
WHAT MONTH
NOVEMBER
THE '07?
GRANDMA
IN NOVEMBER --
THE COURT:
YOU HAVE
IT DOWN AND
BREAK
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IT INTO
SOME
SEGMENTS TO DEAL YOUR GRANDMOTHER WITH IT. ARE YOU AWARE IN NOVEMBER 2007. I WAS AWARE
WAS
HOSPITALIZED
THE WITNESS:
OF
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HOSPITAL, YES.
THE COURT: THAT TIME PERIOD, NOVEMBER 2007?
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Q
YOUR GRANDMA, RIGHT, YET THERE IS NO RECORDS OF NOVEMBER OF YOU HAVING CONTACTED YOUR GRANDMOTHER, BECAUSE IF YOU CONTACTED YOUR GRANDMA WHEN SHE WAS DYING, IT WOULD SHOW HERE, RIGHT? 370-0685? THIS IS HER PHONE, RIGHT? THE PHONE IS
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OBJECTION.
IT'S IRRELEVANT.
IT
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DEED BY WHICH MR. RAMIREZ TAKES TITLE IS IN '06. THE COURT: BY MR. CASTANEDA: Q
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OBJECTION SUSTAINED.
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OBJECTION.
ALREADY SUSTAINED THE OBJECTION AND I ASK THE COURT FOR A MOTION TO STRIKE. THE COURT: THE TESTIMONY CAN STAND AS TO THE
PHONECALL MR. ALONZO CASTANEDA SAYS HE MADE TO DEFENDANT JOSE CASTANEDA. AND I AM UNCLEAR WHETHER OR NOT THERE IS
I TIME,
NOVEMBER 2007?
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THAT'S WHAT THE RECORD IS. MR. CASTANEDA: CASTANEDA'S PHONE RECORDS. THE COURT: I DON'T KNOW THAT RIGHT NOW. NO ONE THE RECORDS DO SHOW THIS IS MS.
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OF 2007?
THE WITNESS: I SPOKE TO HER. I BELIEVE I
CALLED HER FROM MY CELLPHONE DIRECTLY AS ME AND MY SISTER WHO OCCASIONALLY HANG OUT AND BOND, HER TELEPHONE NUMBER WAS ON THAT. THE COURT: THE WITNESS: NUMBER. BY MR. CASTANEDA Q YOU DON'T KNOW WHETHER YOU CONTACT MR. CASTANEDA: RECORD. THE COURT: HE SAID HE CALLED YOUR NUMBER, BUT THE AREA IS STATED ON THE WHEN YOU SAY HER CELL PHONE NUMBER CORRECT. MY SISTER'S CELL PHONE
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NEVER GOT HOLD OF YOU. MR. CASTANEDA: THE COURT: HE NEVER REALLY CONTACTED ME.
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ANSWER THE PHONE. MR. CASTANEDA: ALL RIGHT. THIS IS THE LAST.
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THEY DON'T HAVE ANY CLIENTS. THE COURT: WHAT ARE THEY? RECORDS GOING TO
SHOW ME IT WAS TRANSFERRED FROM YOUR MOTHER'S ACCOUNT. MR. CASTANEDA: THE COURT: YES.
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MR. CASTANEDA:
THE COURT:
MR. CASTANEDA:
NO.
3574695.
I SHOW A
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MONIES TRANSFERRED FROM MRS. CASTANEDA'S ACCOUNT. THE COURT: SUBJECT TO A MOTION TO STRIKE, SEE DO YOU SEE IF IT'S HIS
DO YOU RECOGNITION THAT AND THAT ACCOUNT NUMBER? THE SIGNATURE IS BLANK -- FELICITASS. FELICITAS
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CUSTOMER A Q A
Q
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THAT'S
NOT MY NAME. I SAID, DID YOU WRITE THAT NAME, MS. CASTANEDA,
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ON THIS ACCOUNT? A DID NOT. Q THANK YOU. DID YOU WRITE A NO, I DID NOT. TRANSFER AMOUNT WHAT IS THE EXACT THE NUMBER AS WELL? I KNOW WHAT YOU JUST SAID. I SAID I DON'T. I
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Q
AMOUNT? A
LOOK
$25,000.
READ THE ACCOUNT? A ACCOUNT, I CANNOT. ACCOUNT LOOK TO BE A LINE DRAWN NUMBER, THROUGH IT SOME
TRANSFER
AND UNDERNEATH
MORE NUMBERS.
OKAY.
TRANSFER,
AND
SEE
IF YOU RECOGNIZE
HERE?
A
Q
IS THAT
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A
Q
THE ACCOUNT
A
Q
6246695.
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RIGHT.
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2
A COMMA.
Q
ZEROS SAID
BEHIND
ITbNP
NO
$10,000.
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IS THIS YOUR
SIGNATURE?
A Q
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6 7
OKAY.
SIGNATURE
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NO,
IS THAT NO,
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A
Q
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CAN YOU TELL ME WHAT THIS CASH. FOR HOW MUCH? $5,000. AND THIS TOTAL THANK HERE? $5,000.
LINE
A
Q A Q
A
Q
NUMBER, NUMBER?
YOU SAID
IT WAS
ACCOUNT
877 DASH
IS A LITTLE SO MUCH.
BIT HAZY.
CASTANEDA: THAT
THE COURT:
MS. MACCARLEY:
LIKE A MOTION TO STRIKE AS TO THE QUESTIONS AND ANSWERS PERTAINING TO THOSE ~ITHDRA~AL SLIPS.
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THE COURT:
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WITNESS STAND. THE WITNESS: THE COURT: JUDGE, DO I TAKE THIS WITH ME? NO. LEAVE IT FOR THE NEXT WITNESS. I HAVE A COUPLE MORE.
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YOU JUST TOLD ME YOU WERE DONE. HE HAS A COUPLE MORE QUESTIONS FOR LET'S HAVE YOU RETAKE STAND.
SHOW THE DOCUMENT TO COUNSEL. MS. MACCARLEY: YOUR HONOR, I WOULD ASK THAT THE
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15 I NONE OF THESE CHECK HAVE ANYTHING TO DO WITH EITHER OF THE 16 PLAINTIFFS. THEY ARE ALL MADE OUT ON TO OTHER PARTIES WHO THEY HAVE
GONZALO CASTANEDA, FOR EXAMPLE, AND IS COMPLETELY THERE IS ONLY ONE HOW IS THIS WITNESS GOING TO TESTIFY
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THE COURT:
ABOUT CHECKS MADE PAYABLE TO SOMEONE ELSE? MS. MACCARLEY: MY CLIENT'S NAME AND PHONE
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AM SORRY -- NAME AND SIGNATURE CLEARLY DO NOT APPEAR ON ANY OF THESE RECORDS. MR. CASTANEDA: I AM TRYING TO ESTABLISH THAT
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THE COURT:
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THE MOTHER. PHYSICALLY PRESENT WHEN SOMEONE WERE YOU CHECK FROM YOUR MOTHER? THE WITNESS: THE COURT: MY GRANDMOTHER, NO. I AM SORRY. I KEEP DOING THAT.
SHE IS SHOWN.
DOCUMENTS UNLESS HIS NAME APPEARS OR HIS ACCOUNT NUMBER. BY MR. CASTANEDA: Q WHAT ABOUT THIS ONE? MR. CASTANEDA: MS. MACCARLEY: OBJECTION. OBJECTION, RELEVANCE. MY CLIENT
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I DOCUMENTS
THE THOSE DOCUMENTS. IGONE THROUGH HIS NAME ON IT -- COURT: I HAVEN'T DON'T HAVE THE
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1~lO~
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ACCOUNT NUMBER.
2 , BY MR. CASTANEDA
Q
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BY MR. CASTANEDA:
Q
THIS? AGAIN, NOT MY NAME. WHAT ABOUT THIS? DO YOU RECOGNIZE WHO IT IS
A
Q
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PAID TO?
A
Q
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IT'S NOT MY NAME. YOU ASKING WHO PAID TO -SUSANA CASTANEDA. WHO IS SUSANA? SHE IS MY MOTHER. WHAT AMOUNT? LOOKS TO BE $2,000. MS. MACCARLEY: THE COURT: OBJECTION, YOUR HONOR.
A
Q
A
Q
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THOSE DOCUMENTS -MR. CASTANEDA: THE WITNESS: MR. CASTANEDA: THE COURT: WHAT ABOUT GONZALO'S? NOT MY NAME. THIS IS --
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FOUNDATION FOR THE WITNESS'S TESTIMONY. ANYTHING FURTHER? MS. MACCARLEY: THE COURT: NO QUESTIONS.
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NEXT WITNESS.
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EVELYN CHRIS~JNA_RAMIREZ, CALLED AS A WITNESS ON BEHALF OF THE PLAINTIFF WAS DULY SWORN AND TESTIFIED AS FOLLOWS:
5 6 7 8 9 SWORN.
THE CLERK:
YOU DO SOLEMNLY SWEAR THAT THE TESTIMONY YOU MAY GIVE IN THE CAUSE NOW PENDING BEFORE THIS COURT SHALL BE THE TRUTH, THE WHOLE TRUTH AND NOTHING BUT THE
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DIRECT
EXAMINATION
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YOU, AND THERE IS A TAB THAT IS, PERHAPS, STILL TURNED TO EXHIBIT SIX. A Q UH-HUH. DO YOU SEE THAT?
YE S , I DO.
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A Q
YES. AND DO YOU SEE THE NAME EVELYN OF THE DOCUMENT? I DO. CHRISTINA RAMIREZ THAT IS ON CHRISTINA RAMIREZ
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MA'AM. THE COURT TO PARTITION BY AND ARE YOU ONE-THIRD IS 'THE SUBJECT TO THIS YBS, TITLE ARE THE REQUESTINGTHAT OWNER OF THE PROPERTY? DEED? YES, YOU PROPERTY TO PROPERTY?
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YESr
THE COURT:
MAY I APPROACH
THE WITNESS
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DO YOU HAVE ANY DOCUMENTS? MR. CASTANEDA: SHE ALREADY -THAT SHOW THIS
CHRISTINA
RECEIVED?
BETWBEN
COUNSEL
OUT
OF THE REPORTER.)
RECEIVED
BY EVELYN?
CASTANEDA:
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THE COURT:
ALL RIGHT.
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CASTANEDA: DON'T KNOW WAS --OR CAN TESTIFY MACCARLEY: CAN HERTHAT HOW SHE ONES. ACCOUNT TO MS. THE ONE SIGNATURE I BEAR SHOW HER OTHER HER ON
MR. THE COURT: N THE MONEY WAS TRANSFERRED. AND TELL ME IF SHE WAS THE COURT:
A
Q
YOU HAD GRANDMA? AND YOUR LUNCH. AND SHE SAID SHE WANTED WE THE LUNCH? YES. DISCUSSED ME. SHE CALLED YOU? WITH APPROACHED IT. ---
A Q A Q
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A Q A Q
AT COCO'S
ON LAKE.
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4
5
6 7 8
9
A
Q A
NO.
WHEN THIS YES. DATE DID YOU GO TO MAKE THE BONA GRANT DEED? WHAT'S ON HERE 14TH? THIS WHAT FIDE TRANSFER?
Q
A Q A Q DOCUMENT BECAUSE A Q
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JANUARY YES.
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ARE YOU ALSO AWARE PREPARED MY ATTORNEY RIGHT. DO YOU KNOW I DON'T IN ENGLISH/ AGAIN
HAS?
IF ANOTHER
DOCUMENT
WAS? REMEMBER,
A
HONESTLY. Q
REMEMBER.
BUT -- I DON'T
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OKAY. WILL IT REFRESH YOUR MEMORY IF I HAD THAT IF THAT DOCUMENT WITH
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HAS YOUR
SIGNATURE?
OTHER NO.
I CAN'T
IN ENGLISH/
SHE DIDN'T
READ OR WRITE
ENGLISH?
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2
A
Q
WAS VERY
AWARE,
YES.
HOW
FOR THAT
POWER
OF
TO BE SIGNED
MS. MACCARLEY:
OBJECTION.
CALLS
FOR
STATE
OF MIND. FOUNDATION.
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LACKS
LET ME ASK YOU, DID YOU ASK MR. REYES ANOTHER DID DOCUMENT BESIDES THIS? ANOTHER
TO
WITHDRAW A
Q
DOCUMENT? SPECIFIC
THERE
SIGNED
ON THAT
DATE? A
Q
I DON'T
REMEMBER.
REMEMBER?
THE COURT:
EXPLAINED
TO YOUR
GRANDMOTHER
AND
RAY? NOTARY PAPERS. RAY WAS BELIEVE RAY YES. PUBLIC? I EXPLAINING IS THE ... THE -YES, THE THE COURT:
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THAT'S
HIS
IN ENGLISH
OR
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12
THE WITNESS:
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BY MR. CASTANEDA DOCUMENT WAS IN ENGLISH? Q BUT THE A Q A Q A Q A Q A WELL, OBVIOUSLY. IS THIS DOCUMENT IN ENGLISH? YES. IT IS IN ENGLISH, RIGHT? YES. ARE YOU AWARE SHE UNDERSTANDS WHAT GRANT DEED YES. SHE HAS DONE IT BEFORE. SEVERAL TIMES.
SHE DONE IT BEFORE? SHE HAD SIGNED BEFORE. HOW DO YOU KNOW? YOU CAN SEE IN THE OTHER EXHIBITS SHE SIGN OVER SHE WASN'T COMPLETELY COULD
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SUSTAINED.
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BY MR. CASTANEDA TO ASK YOU REGARDING THIS -- THIS IS YOUR Q I WANT SIGNATURE? A
Q
MY SIGNATURE?
NO, SIR.
NOT MY SIGNATURE.
NOT MY WRITING.
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2
Q A Q A
Q
IT'S NOT YOUR WRITING? NOT MY WRITING. DO YOU KNOW WHO PREPARED THIS? I DON'T REMEMBER. ON~ECEMBER 2, 2005, ARE YOU AWARE OF $5,000 WAS
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I DIDN'T KNOW THEY ARE TRANSFERRED. YOU DON'T KNOW IF IT WAS TRANSFERRED? IT'S SHOWING SOMETHING TRANSFERRED.
I MEAN ...
THAT'S ALL
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GRANDMOTHER IN DECEMBER OF 2005? THE WITNESS: THE COURT: ZERO FIVE? IF YOU REMEMBER.
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WHAT WAS THE AMOUNT? MR. CASTANEDA: THE COURT: GRANDMOTHER? THE WITNESS: BY MR. CASTANEDA: Q LET ME JUST REFRESH YOUR MEMORY. IN 2006, I BELIEVE IT WAS JUNE, YOU TOOK A TRIP TO MEXICO, RIGHT, PUERTO VILLARTA? THAT? A YEAH, SURE. DO YOU REMEMBER DID I RECEIVE IT? NO. $25,000.
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ON THE TRIP?
A
Q
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4
A
Q
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AND SHE IS PRESENT YES. YOU ARE AWARE WHO? ALICIA? YEAH. KNOW WHAT I THINK SHE DOESN'T THESE THAT
IN THE COURT?
A
Q
SHE ONLY
SPEAKS
SPANISH?
A
Q
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SPEAK
ENGLISH. IS ABOUT?
PROBABLY
DOESN'T
Q
PROCEEDINGS
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THE RELEVANCY
QUESTION.
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BY MR. CASTANEDA
Q
OBJECTION
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I DON'T
KNOW
WHAT
HAPPENED.
A
Q
THIS
I KNOW THAT'S
A
Q
23
24
A
Q
NOT MY WRITING.
25 26
27
LET ME PRESENT
I APPROXIMATELY A
WHICH
IS WRITING?
THREE
WEEKS,
RIGHT?
IS YOUR
28
THAT'S
NOT MY WRITING.
49
1
2 3
THAT'S THAT'S
NOT YOUR
WRITING?
NOT MY WRITING.
A Q
A
Q
IS YOUR
6 7 8
A Q A
9 10
11 12 13
Q A
HEART.
OKAY.
YOU DON'T. CAN YOU LOOK UNDER HERE WAS THE COMPANY?
14
15 16 17 18 19 20 21 22 23 24 25 26 27
357. SO, IT WOULD TO GET MORE BE WITH YOU JUST FOR THE SAKE WAS OF
I I
Q TRYING
DOCUMENTS,
IS THAT AMOUNT
TRANSFERRED
SPECULATION. IRRELEVANT.
LACKS
FOUNDATION.
IT IS HEARSAY.
IT IS RELEVANT,
YOUR
HONOR. SURE
I AM NOT IT.
MS. CASTANEDA
THE IMPRESSION
WE DON'T
28
NOT HERE
TO TELL
50