Case 2:15-cv-00782-JTM-JCW Document 182-2

177-4 Filed 05/19/16

05/18/16 Page 1 of 4

UNITED STATE S DI STRI CT COURT

EAS TE RN DI STRI CT OF LOUI S I ANA

TH OMAS MILT ON BEN SON, J R .,

in hi s capac it y as GRANT OR

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CI VIL AC TI ON NO. 1 5 - 782

SECTI ON: H

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VERS US

JUDGE MILAZZ O

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RO BE RT A . ROS ENTHAL,

in

hi s capac it y as TRUSTEE

MAG . DI VI S I ON: 2
MAG . JUDGE WIL KINSON

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* * * * * * * * * * * * * * *

Video t aped d epos iti on o f TH OMAS MILT ON BEN SON,

J R ., t a ken i n hi s o ffi ces l oca t ed a t

5800 Airli ne Dri ve ,

Me t a iri e , Lo ui s i a n a 70003 , on th e 28 th day o f Ma r c h,

2016 , b eg i nn in g a t

9 : 32 a . m.

REPORTED BY:
CONNIE M. FINE SCHI, CCR
CERTIFIED COURT REPORTE R

Case 2:15-cv-00782-JTM-JCW Document 182-2

177-4 Filed 05/19/16
05/18/16 Page 2 of 4
CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER
Page 17

A.

Yes.

Q.

What was the verbal attack?

A.

They came to the house, and I had been

ill and they attacked her there.

Q.

Were you -- Did you witness this attack?

A.

Verbally?

Q.

Yes.

A.

Yes.

Q.

And what was the verbal attack?

10

A.

I don't remember.

11

Q.

And you said they.

12

"they"?

13

A.

It wasn't good though.

Again, who are the

I don't know if all three of them were

14

there or not, but Renee was one of them.

15

Renee and Rita.

I think

16

Q.

And when was this?

17

A.

When was it?

18

Q.

Yes, sir.

19

A.

I don't remember the exact date, but over

20

a year ago.

21

Q.

Do you know whether you have created

22

trusts for the benefit of your daughter and your

23

grandchildren?

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Rita LeBlanc, and Ryan LeBlanc?

25

A.

And to be particular, Renee Benson,

Right.

ON THE RECORD, INC.

(504) 378-3850

Case 2:15-cv-00782-JTM-JCW Document 182-2

177-4 Filed 05/19/16
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CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER
Page 18

Q.

Did you create trusts for their benefit?

A.

Yes.

Q.

Okay.

A.

Yes.

Q.

And what are you asking the Court to do

And you did create those trusts?

with respect to those trusts in this lawsuit?

A.

That was the advice of attorneys.

Well, I want to take the money out of

them that would have gotten in there.

Q.

And leave what?

10

A.

Zero.

11

Q.

So is it --

12

A.

They attacked me, you got to know.

13

That's why I don't want to leave them anything.

14

Okay?

15

Q.

All right.

So -- And in respect of the

16

attack that you perceived, you would like to leave

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zero dollars in the trusts?

18

A.

Well, I found out they didn't love me

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very much, trying to stab me in the back, wanted to

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take over everything, brought me to court saying I

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was crazy.

22

Q.

You don't need any more than that.

And so if the Judge would do your

23

bidding, how much money would be left in the

24

trusts?

25

A.

I don't know.

ON THE RECORD, INC.

(504) 378-3850

Case 2:15-cv-00782-JTM-JCW Document 182-2

177-4 Filed 05/19/16
05/18/16 Page 4 of 4
CONFIDENTIAL AND SUBJECT TO PROTECTIVE ORDER
Page 19

Q.

I mean your desire?

A.

A guess?

Q.

Do you want to leave something in the

trust or nothing in the trust?

A.

Today nothing.

Q.

Let me show you a document, sir.

talking about trusts.

of a particular trust.

13

We'll call this TB-1.

Exhibit TB-1.)

10

12

I'm going to show you a copy

(Document marked for identification as

11

We're

EXAMINATION BY MR. FLANAGAN:

Q.

Mr. Benson, do you recognize that

document?

14

A.

No.

15

Q.

All right.

16

A.

When was this done?

17

Q.

Well, let me ask you to turn to the

If you can

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second-to-last page.

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that's your signature where it says Grantor?

20

A.

Yes.

21

Q.

All right.

If you would, sir, tell me if

And it says this --

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" ... effective as of the close of business on the

23

31st day of December, 2012."

Do you see that?

24

A.

Yes.

25

Q.

Do you know whether there is a trust that

ON THE RECORD, INC.

(504) 378-3850