21

1
2

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

3
4

YOU WANT TO SHOW MY CLIENT A CHECK SHE

5
6
7

I DON'T SEE THE RELEVANCE ( BUT I

8 9

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

10

11
12 13 14 15 16 17 18 19 20 21 22 23 24 25 26

I DON'T KNOW THAT HE GOT THIS CHECK OR ASK HIM ABOUT THE CHECK YOU SAY

CASHED IT OR WHATEVER. WAS PAYABLE TO HIM. MR. CASTANEDA:

OKAY.

PROBABLY GOING TO NEED TO

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

(DEFENDANT'S EXHIBIT A WAS MARKED FOR IDENTIFICATION: CHECK.)

27
28

THE COURT:

I DON'T HAVE IT IN FRONT OF ME.

IS

YOUR NAME ON THE CHECK?

22

I
I

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

2 I 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

MAY I CONTINUE WITH THE

I AM TRYING TO FIND OUT.

DO YOU KNOW IF YOU RECEIVED THAT CHECK OR DO YOU RECALL?

I
PLAUSIBLE.

THE WITNESS:

I DON'T RECALL, TELL YOU THE I CAN SEE IT'S

TRUTH, SEEING IT IS ON MY BIRTHDAY.

THE COURT: THE WITNESS: THE COURT: BY MR. CASTANEDA: Q

YOU DON'T RECALL AT THIS POINT? NOT OFF THE TOP OF MY HEAD. GO AHEAD, MR. CASTANEDA.

I WILL ASK YOU EARLIER THAT YOU CONTACTED ME TO

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

23

11~!\LLED 2

SEVERAL YOU AND

TIMES

AND

I LEFT

11' Y)? TO MY ATTORNEY

TO

I
I

CONTACT
Q

PROCEED

THAT WAY. YOU SAID YOU CONTACTED ME TO

3
4 5

WAIT A MINUTE.

SELL THE HOUSE. THE ATTORNEY A

NOW YOU ARE SAYING

YOU SAID YOU CONTACTED

I I I
I

TO SELL THE HOUSE? I TRIED UP. TO CONTACT YOU AT YOUR FOR ME TO

6
7 8 9 10

I AM SAYING NO ONE PICKED INFORMATION

HOUSE.

NO ONE WAS AVAILABLE

GIVE THAT

TO YOU TO SUGGEST

TO SELL THE HOUSE. TO CONTACT

SO, I LEFT YOU AND GIVE

Q

IT UP TO MY ATTORNEY

THAT

YOU INFORMATION. YOU RESIDE LOS OSOS, WHERE? CALIFORNIA.

11
12 13 14 15 16

OKAY.

A
Q

I RESIDE WHAT

IS THE ADDRESS?

A
Q

174017. HOW DID YOU PURCHASE I DID NOT PURCHASE THAT HOME?

A
Q

THAT HOME. PURCHASE THAT HOME?

17
18 19 20

HOW DID YOUR MOTHER MS. MACCARLEY: MR. CASTANEDA:

OBJECTION. BECAUSE

RELEVANCE. GAVE THEM RIGHT THE

MY MOTHER THEY RESIDE SO WHAT?

DOWN

PAYMENT

FOR THAT

HOME WHERE IF SHE DID,

NOW.

21 22
23 24 25 26 27 28

THE COURT:

MR. CASTANEDA:

I AM TRYING

TO ESTABLISH THAT HE HAS CHARACTER AND ME

THAT

THE WITNESS

MISREPRESENTED

ON THE RECORD ABOUT

I
I I I

CONTACTED

ME TO DO THAT.

I AM TALKING

THE WAY HE IS NOT BEING, REGARDING SELLING

YOU KNOW, AS FAR ) AS CONTACTING THAT PHONECALL. ISSUE THAN THE

THE HOUSE, THAT

THE COURT: WHETHER

IS A DIFFERENT

OR NOT HE OWNS HIS HOUSE

UP IN LOS OSOS.

24

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

COURT HOUSE

IS GOING

TO SUSTAIN

THE OBJECTION MATTER.

HOW HE GOT THE

IN LOS OSOS DOESN'T

BY MR. CASTANEDA:

DID YOU EVER MS. MACCARLEY: THE COURT:

SMOKE

POT IN FRONT

OF YOUR

GRANDMA?

OBJECTION.

RELEVANCE. WILL BE SUSTAINED. I DON'T KNOW WHAT IT I

THE OBJECTION

REALLY

DOESN'T

TO GO ANYTHING

HE DID.

WOULD.INFER

FROM

IT IF IT WAS TRUE. WELL, HE TALKS SAYING ABOUT CHARACTER, ME

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

TO MR. REYES' -- WHO MADE

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

THE COURT: THE WITNESS:

GO AHEAD. I DO NOT KNOW.

21 22

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.

THE COURT: 23 THE WITNESS: THE WITNESS: THE COURT: COURT: 24

25
26

27
28 MR. CASTANEDA: THAT MR. REYES ARTURO REYES?

25

1
2

unidentified spe~~~: THE WITNESS: SERVICE. BY MR. CASTANEDA

Q

ARTURO.

I KNOW IT'S REYES TAX COMPANY

3
4

5
6 7 8 9 10

WERE ARE HIS OFFICES?

DO YOU KNOW?

A
Q

I BELIEVE ONE IS IN LYNWOOD. OKAY. YOUR HONOR, MR. ARTURO REYES IS A

COMPLETELY DIFFERENT PERSON THAN THE ONE THAT THE COURT: ALL THAT. YOU'RE GOING TO HAVE TO TESTIFY ON

11
12 13 14 15 16

YOU ARE GOING TO HAVE TO GET ON THE WITNESS SAVE IT

STAND AND TELL ME IT'S NOT EVIDENCE FROM COUNSEL. UNTIL YOU ARE ON THE WITNESS STAND. BY MR. CASTANEDA: Q

HOW IS IT YOUR GRANDMA WENT WITH YOU AND SUSANA

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

17
18 19 20

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

21
22 23
24

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.

25 26 27 28

26

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 HAVE GIVEN

THE COURT: BY MR. CASTANEDA: Q OF ATTORNEY FELICITASi

NEXT

QUESTION.

DID YOU KNOW ON THAT EXACT IN ENGLISH SIGNED

DATE

THERE MRS.

IS A POWER CASTANEDA,

BY MY MOTHER

ARE YOU AWARE MS. MACCARLEY: MR. CASTANEDA:

OF THAT? OBJECTION. THAT'S THE EXHIBIT MR. COUNTS

HAS AS WELL. MS. MACCARLEY: THE COURT: OBJECTION. THE POWER IT WAS RELEVANCE. OF ATTORNEY ISSUED SHOW?

WHAT'S

MR. CASTANEDA: TO THEMI BOTH

THAT
I

-- IT WAS SPOKE

OF THEM

IN ENGLISH.

MY MOTHER

ONLY SPANISH. THE COURT: IN FRONT SO, THERE IS A DOCUMENT WE DON'T

OF US TODAY? CORRECT. WOULD BE A

MR. CASTANEDA:

THE COURT: POWER ATTORNEY

YOU ARE REPRESENTATION THE SAME DATE? SAME DATE BY MISTER

OF EXECUTED

19
20 21 22 23 24 25 26 27 28 POWER

MR. CASTANEDA: THE COURT: OF ATTORNEY?

YOU CAN ASK:

ARE YOU AWARE

OF THE

I
I

BY MR. CASTANEDA:

ARE YOU AWARE

THERE
MEI

IS A POWER

OF ATTORNEY

WHICH

I I DON'T HAVE IN FRONT OF I REYES I NOT ARTURO REYES I

PEOPLE. A CAN YOU PLEASE IN THERE.

BUT ARE YOU AWARE

OF THAT MR. DIFFERENT

THEY ARE TWO COMPLETELY

STATE

YOUR

QUESTION

AGAIN.

THERE

IS TOO MANY

27

1 2 3 4 S 6 7 8 9 10 11 12 MR. REYES?

THE COURT:

ARE YOU AWARE OF A POWER OF ATTORN~Y

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

THE WITNESS: THE COURT:

THE WITNESS: THE COURT: THE WITNESS: BY MR. CASTANEDA:

ON THAT SAME DAY? APPARENTLY. I DID NOT. NO.

ARE YOU AWARE POWER OF ATTORNEY HAS YOUR

13 14 15 16 17 18
19 20

SIGNATURE MS. IT? ON MACCARLEY: EVIDENCE.

OBJECTION.

ASSUMES FACTS NOT IN

HE ALREADY TESTIFIED HE DIDN'T KNOW ABOUT A

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

21 22 23 24 25 26 27
28

THING I DID WAS SIGN WAS THE HOUSE. MR. CASTANEDA: THE COURT: MAY I TAKE A MOMENT? I MIGHT --

GO AHEAD. YOUR HONOR, I BELIEVE MR. COUNTS BUT I DO

MR. CASTANEDA: HAS THAT.

I
I

NO, YOUR HONOR, I DON'T HAVE THAT.

HAVE SOMETHING ELSE. THE COURT: GO AHEAD.

28

1 2 3 4 5 6 7 8 9 10 11 12
13

MR ._J;,ASTANEDA: IF I MAY. THE COURT: SHOW IT TO THE ATTORNEY FIRST. THIS IS MY MOTHER'S PHONE

MR. CASTANEDA: RECORDS. MS. MACCARLEY: OF PHONE RECORDS. THE COURT:

IT IS IRRELEVANT.

JUST COPIES

COPIES OF WHAT? SOME KIND OF PHONE RECORDS. CELLPHONE RECORDS. CELLPHONE RECORDS. THERE IS NO

MS. MACCARLEY: MR. CASTANEDA: MS. MACCARLEY: AUTHENTICATION. THE COURT:

DO YOU KNOW WHOSE CELLPHONE -YES. IT'S MY MOTHER'S CELLPHONE

MR. CASTANEDA: NUMBER. MS. MACCARLEY: THE COURT: GRANDMOTHER? MS. MACCARLEY:

14 15 16 17 18 19 20 21 22 23 24 25 26
J

COMPLETELY IRRELEVANT.

DO YOU KNOW -- SO, THIS IS YOUR

RIGHT.

I
I I

THE COURT: CELL PHONE NUMBER? THE WITNESS:

DO YOU KNOW YOUR GRANDMOTHERJS

OFF THE TOP OF MY HEAD, NO.

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.

27 28

BUT THAT THE PHONE CALL WAS MADE SWEDEN SHOULD SHOW HERE IF MY MOTHER MADE PHONECALLS TO SWEDEN. IT IF MY MOTHER

29

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20

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

I
I I

I
I

ALL IT WOULD SHOW ME IS THAT A PHONECALL WAS MADE

EITHER TO OR FROM THAT LOCATION TO A NUMBER IN LOS OSOS. MR. CASTANEDA: THE COURT: THAT'S FINE.

THAT'S WHAT IT WOULD SHOW ME. ALL RIGHT.

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

CONTACT WITH HER AT LEAST, I WOULD SAY, ONCE OR THREE

21 22 23 24 25

TIMES A MONTH. CASTANEDA: MR.

YOUR HONOR, IT WILL SHOW

THAT THE PLAINTIFF, JUST LIKE MRS. RAMIREZ, DID NOT VISIT MRS. CASTANEDA SINCE -- FOR A COUPLE OF YEARS THE LAST YEARS OF HER LIFE.

26 27 28

I ALREADY TAKEN THE IT I DIRECTED HER INTO

WILL SHOW THAT PRIOR TO DISAPPEARING HER $70,000 AND THEY ALREADY OBVIOUSLY SIGNING THIS QUIET TITLE TO THEM. THE

30

1
2

PHONE CALLS. SHOW BAS ICAL.LY ..FROM NOVEMBERH_20.Q2

.... _._._-----~--_._-_.....

WHEN MS. I WANT WAS SENT

CASTANEDA TO KNOW MRS.

WAS

IN THE HOSPITAL. ON THE RECORD

AND FOR THE RECORD, THAT MRS. MACCARLEY OF RECORD, HER. THE YET SHE

3
4

-- STATE

SUSANA

CASTANEDA'S

ATTORNEY

5 6
7

TWO PEOPLE

TO THE HOSPITAL THE COURT:

TO QUESTION

WE ARE GETTING

WAY OUTSIDE

RECORD.

I HAVEN'T FACTS.

HAD ANY TESTIMONY

ON ANY OF THESE

FACTS

8 9 10

OR SUPPOSED

MR. CASTANEDA: WOULD HAVE BEEN. I THINK

IF I HAVE HAD BEEN, MR. THAT WOULD I DON'T

COUNTS

11
12 13 14 15 16 HE DIDN'T INDICATION TO HAVE MR. COUNTS

THE COURT: --

AM SORRY.

KNOW WHAT

MR. CASTANEDA: THE COURT: CONTACT 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

THAT WAS ABOUT. THAT UP WITH

I SUSPECT

17
18 19 20 21 22
23

TO TAKE

THE BAR ASSOCIATION

MR. COUNTS. BUT, AT ANY RATE, THE PHONECALL, PHONECALLS THE GENTLEMAN THE ISSUE YOU HAD ABOUT IS A NUMBER OF

SAID THERE

FROM HIS GRANDMOTHER MR. CASTANEDA:

TO HIM AND FROM LOS OSOS. ONE OF THAT

I WANT TO KNOW WHICH

THESE

PHONECALLS

ARE TO HIM, AND IS ONE OR THE NUMBER ME. -- YOU ARE ASKING A

24 25 26 27 28

HE APPARENTLY

CONTACTED

THE COURT: DIFFERENT QUESTION. REFRESHES

YOU CAN SHOW

YOU CAN SHOW HIM THAT DOCUMENT HIS RECOLLECTION

AND

SEE IF THAT NUMBER

WHAT HIS CELL PHONE HIS

WAS AT THE TIME WAS OR HIS CELL PHONE HE REACHED

31

1I
2 3 4
5
6

GRllliDMOTHER.

MS. MACCARLEY: BASED ON THE RELEVANCE. THE COURT: GOING TO BE. MS. MACCARLEY: MR. CASTANEDA:

I WANT TO MAKE AN OBJECTION

I DON'T KNOW WHAT THE RELEVANCE

IS

EXACTLY. IT IS RELEVANT

7 8

THE COURT:

HAVE HIM LOOK AT THE DOCUMENT FIRST.

10 9 11 12 13 14 15 16 17 18 19 20 21

I
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:

THE ONES THAT SAY SAN LUIS

I
I

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.

I I I

22 23 24 25
26

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

27 28

I
I

THE COURT:

BE SUSTAINED ON RELEVANCY GROUNDS.

32

MS. MACCARLEY: 2 3
4

OBJEC,:[,LQN~_ RELEVANCY. HE CAN'T

THE COURT:

IT'S NOT HIS NUMBER.

TESTIFY. MR. CASTANEDA: I UNDERSTAND THAT.

5
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22

THE COURT: MR.

IT'S NOT RELEVANT. I UNDERSTAND PHONE CALLS. QUESTION. THERE IS INCOMING

CASTANEDA:

PHONECALLS

AND OUTGOING THE COURT:

JUST ASK YOUR NEXT

I
I I I I

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

THE NOVEMBER BELIEVE

-- I AM SORRY STARTS

SAYS HERE DECEMBER, AND GOES UNTIL

THE DATE

ON 11/14/07

11/29. YOUR

SEE, FOR A WHOLE GRANDMOTHER WAS IN THE HOSPITAL

MONTH, DYING?

ARE YOU AWARE

MS. MACCARLEY: THE COURT:

OBJECTION.

RELEVANCE. ABOUT?

WHAT MONTH

ARE YOU TALKING OF '07. IS THAT OF

MR. CASTANEDA: THE COURT:

NOVEMBER

YOUR REPRESENTATION DYING

THE '07?

GRANDMA

WAS IN THE HOSPITAL MR. CASTANEDA:

IN NOVEMBER --

AND HE SAID TO SLOW

THE COURT:

YOU HAVE

IT DOWN AND

BREAK

23 24 25 26

I I

IT INTO

SOME

SEGMENTS TO DEAL YOUR GRANDMOTHER WITH IT. ARE YOU AWARE IN NOVEMBER 2007. I WAS AWARE

WAS

HOSPITALIZED

THE WITNESS:

SHE IS IN AND OUT

OF

27 28

I THE

HOSPITAL, YES.
THE COURT: THAT TIME PERIOD, NOVEMBER 2007?

33

1 2 3 4 5 6 7 8 9 10 11
12

I
I
Q

THE WITNESS: THE COURT: BY MR. CASTANEDA:

YES. NEXT QUESTION.

SO, AGAIN, YOU SAID ON THE RECORD YOU CONTACTED

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

I
I

MS. MACCARLEY: CALLS FOR HEARSAY.

OBJECTION.

IT'S IRRELEVANT.

IT

THERE HAS BEEN NO EVIDENCE SHE IS IN '07. THE

THE HOSPITAL, THAT'S IRRELEVANT, IN NOVEMBER

13
14

DEED BY WHICH MR. RAMIREZ TAKES TITLE IS IN '06. THE COURT: BY MR. CASTANEDA: Q
J

OBJECTION SUSTAINED.

15 16 17

SO, YOU DO WANT ME -- THERE IS NO PHONECALLS

MADE TO MRS. CASTANEDA, AS WELL AS NO PHONECALLS MADE TO

18 I ME, TO AMANDA; IS THAT CORRECT? 19 20 21 22 23 24 25 26 27

28

MS. MACCARLEY: ARGUMENTIVE.

OBJECTION.

RELEVANCE, THE COURT

THE QUESTION WAS ANSWERED.

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

OTHER PHONECALLS MADE TO THE GRANDMOTHER IN THAT PERIOD OF

I TIME,

NOVEMBER 2007?

JUST THE DOCUMENT OF JOSE SHOWED TO

I ALONSO DIDN'T EVIDENCE ANY PHONECALLS FOR THAT PERIOD.

34

1 2 3 4 5 6 7 8 9

I
I

MR. CASTANEDA: THE COURT:

SO BASICALLY -I'M TELLING YOU

I DON'T KNOW WHAT.

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.

TESTIFIED TO TELL ME THAT. NUMBER THAT IS.

I HAVE NO IDEA WHOSE CELLPHONE

DO YOU KNOW IF YOU CALLED HER IN NOVEMBER

10
11
12

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

13 14 15 16 17 18
19

20 21 22 23 24 25 26 27 28

NEVER GOT HOLD OF YOU. MR. CASTANEDA: THE COURT: HE NEVER REALLY CONTACTED ME.

THAT'S WHAT YOU WOULD ARGUE TO ME

THAT THERE WASN'T CONTACT. MR. CASTANEDA: THE COURT: OKAY.

YOU ARE NOT CONTACTED IF YOU DIDN'T

35

1 2
3

ANSWER THE PHONE. MR. CASTANEDA: ALL RIGHT. THIS IS THE LAST.

4 5 6 7 8 9 10 11
12

(DISCUSSION BETWEEN COUNSEL OUT OF THE HEARING OF THE REPORTER.)

MS. MACCARLEY: THESE.

YOUR HONOR, I HAVEN'T SEEN

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.

TO WHO? WENT INTO AN ACCOUNT AND I

13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 INTO? HAVE--

MR. CASTANEDA:

THE COURT:

DO YOU KNOW WHOSE ACCOUNT IT WENT

MR. CASTANEDA:

NO.

3574695.

I SHOW A

I I

SIGNATURE HERE. SIGNATURE.

I WANT TO KNOW IF HE RECOGNIZES THE

IF HE RECOGNIZES THE SIGNATURE, YOUR HONOR,

MONIES TRANSFERRED FROM MRS. CASTANEDA'S ACCOUNT. THE COURT: SUBJECT TO A MOTION TO STRIKE, SEE DO YOU SEE IF IT'S HIS

IF HE RECOGNITIONS THE SIGNATURE. SIGNATURE OR SOMEBODY ELSE'S. BY MR. CASTANEDA: Q A CASTANEDA. Q

DO YOU RECOGNITION THAT AND THAT ACCOUNT NUMBER? THE SIGNATURE IS BLANK -- FELICITASS. FELICITAS

DID YOU WRITE AND PRINT HER NAME UP HERE,

36

1
2

CUSTOMER A Q A
Q

NAME? DID I? NO, I DID NOT. YOUR NAME?

3
4

THAT'S

NOT MY NAME. I SAID, DID YOU WRITE THAT NAME, MS. CASTANEDA,

5
6 7 8 9 10

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

11
12 13 14 15 16 17 18 19 20 21 22 23 24

Q
AMOUNT? A

DID YOU WRITE

LOOK

TO BE $25,000. TRANSFERRED TO WHAT ACCOUNT? CAN YOU

$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.

LET ME SHOW YOU ANOTHER THAT. IS THAT YOUR WRITING

TRANSFER,

AND

SEE

IF YOU RECOGNIZE

HERE?

A
Q

NO, THAT AND

IS NOT MY WRITING. YOUR ACCOUNT NUMBER?

IS THAT

25
26 27

A
Q

NO, HAS NOT MY ACCOUNT CAN YOU READ 357 DASH

NUMBER. NUMBER FOR THE RECORD?

THE ACCOUNT

A
Q

6246695.

28

RIGHT.

WAS THIS AMOUNT FOR THE TRANSFER?

37

1
2

A COMMA.
Q

IT HAS ONE AND FOUR I AM ASSUMING $10,000. NO, PROBABLY

ZEROS SAID

BEHIND

ITbNP

NO

$10,000.

3
4

IS THIS YOUR

SIGNATURE?

A Q

IT IS NOT. THANK YOU. ONE. ON THAT ACCOUNT?

5
6 7

OKAY.

LET ME SHOW YOU ANOTHER IS THIS YOUR

A
Q

SIGNATURE

8
9

NO,

IT IS NOT. YOUR NUMBERS HERE? NUMBER. SAYS?

IS THAT NO,

10

A
Q

I DID NOT PRINT ACCOUNT

11
12 l3 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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

WITHDRAWAL YOU. AND ACCOUNT

NUMBER, NUMBER?

YOU SAID

IT WAS

WITHDRAWN A NUMBER. THE SAME.

FROM WHAT I DIDN'T THE NUMBER I AM NOT MR.

ACCOUNT

SAY IT WAS WITHDRAWN RIGHT SURE. HERE SAYS

FROM ACCOUNT 171915 LOOKS

877 DASH

THE PRINT THANK YOU

IS A LITTLE SO MUCH.

BIT HAZY.

CASTANEDA: THAT

IS ALL. REDIRECT. NO, YOUR HONOR. BUT I WOULD

THE COURT:

MS. MACCARLEY:

LIKE A MOTION TO STRIKE AS TO THE QUESTIONS AND ANSWERS PERTAINING TO THOSE ~ITHDRA~AL SLIPS.

38

1
2
3 4

THE COURT:

LET ME ALLOW HIM TO PUT~HIS WHOLE

CASE ON. MS. MACCARLEY: THE COURT: NO. NOTHING FURTHER.

LET ME GET THIS GENTLEMAN OFF THE

5
6 7 8

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.

MR. CASTANEDA: THE COURT:

9 I

YOU JUST TOLD ME YOU WERE DONE. HE HAS A COUPLE MORE QUESTIONS FOR LET'S HAVE YOU RETAKE STAND.

10 I THIS IS QUICK ALSO. 11 I YOU MR. CASTANEDA.

12 13

SHOW THE DOCUMENT TO COUNSEL. MS. MACCARLEY: YOUR HONOR, I WOULD ASK THAT THE

14

I
I

COURT OBJECT TO THE PRODUCTION, AND QUESTION ONLY BECAUSE

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

17 I ARE NOT HERE AS WITNESSES, NOT ON THE TITLE.

18 I NOTHING TO DO WITH THIS CASE, AND ANY MONIES PAID TO 19

GONZALO CASTANEDA, FOR EXAMPLE, AND IS COMPLETELY THERE IS ONLY ONE HOW IS THIS WITNESS GOING TO TESTIFY

20 I IRRELEVANT TO THIS. 21 22
23

I
I I I

THE COURT:

ABOUT CHECKS MADE PAYABLE TO SOMEONE ELSE? MS. MACCARLEY: MY CLIENT'S NAME AND PHONE

24 25
26

AM SORRY -- NAME AND SIGNATURE CLEARLY DO NOT APPEAR ON ANY OF THESE RECORDS. MR. CASTANEDA: I AM TRYING TO ESTABLISH THAT

27 \ AGAIN $70,000 WERE TRANSFERRED FROM HER ACCOUNT BEFORE SHE

28 I

DOES THIS ONE FILED TRANSFER.

39

THE COURT:

ASSUMING THAT' S_TR.l.JE, WHAT

2
3 4 5 I 6 7 8 9 10

SIGNIFICANCE DOES IT HAVE FOR THIS GENTLEMAN? TO SHOW THE

MONEY WENT TO HIM OR SOMEHOW INVOLVED HIM? MS. MACCARLEY: MR. CASTANEDA: CASTANEDA OR MR. RAMIREZ THE COURT: YOU WANT TO SHOW HIM THE DOCUMENT, PROBABLY. PROBABLY KNEW WHAT MISS

OTHER PEOPLE RECEIVED CHECKS? MR. CASTANEDA: THE COURT: CORRECT.

I DON'T KNOW HOW HE'S GOING TO BE IF YOU WANT

11
12

ABLE TO TESTIFY WHAT OTHER PEOPLE RECEIVED.

TO ASK IF HE PHYSICALLY WAS THERE WHEN HE RECEIVED THE

13 14 15 16 17 18 19 20 21 22 23 24 25 26

I CHECK FROM I RECEIVED A

I
I

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.

MR. CASTANEDA: THE COURT:

SHE IS SHOWN.

HE CAN'T AUTHENTICATE THOSE

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

CANNOT TESTIFY THERE IS NO COMPETENT EVIDENCE COULD POSSIBLY BE --

27 28

I DOCUMENTS

THE THOSE DOCUMENTS. IGONE THROUGH HIS NAME ON IT -- COURT: I HAVEN'T DON'T HAVE THE
J

40

1~lO~
3
4

ACCOUNT NUMBER.

GIVE HIM THE WHOLE STACK.

2 , BY MR. CASTANEDA
Q

HOW ABOUT THIS, CASTANEDA? THE COURT: THE WITNESS:

HOW MUCH IS THAT?

NONE OF THOSE ARE IN YOUR NAME? NONE HE HAS SHOWED ME YET.

5 6
7 8 9

BY MR. CASTANEDA:
Q

THIS? AGAIN, NOT MY NAME. WHAT ABOUT THIS? DO YOU RECOGNIZE WHO IT IS

A
Q

10

PAID TO?
A
Q

11
12 13 14 15 16 17 18 19

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

THE OBJECTION IS SUSTAINED TO ALL

20
21 22 23 24

THOSE DOCUMENTS -MR. CASTANEDA: THE WITNESS: MR. CASTANEDA: THE COURT: WHAT ABOUT GONZALO'S? NOT MY NAME. THIS IS --

-- ON THE GROUNDS THERE IS NO

25

FOUNDATION FOR THE WITNESS'S TESTIMONY. ANYTHING FURTHER? MS. MACCARLEY: THE COURT: NO QUESTIONS.

26 I 27 28

NEXT WITNESS.

41

1I
2 3
4

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:

PLEASE RAISE YOUR RIGHT HAND TO BE

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

10 I TRUTH, SO HELP YOU GOD. 11 THE WITNESS: YES.

12
13 14
15

THE CLERK: BE SEATED IN THE WITNESS STAND.

PLEASE STATE AND SPELL YOUR FULL NAME. THE WITNESS: EVELYN, E-V-E-L-Y-N; RAMIREZ,

R-A-M-I-R-E-Z. MIDDLE NAME CHRISTINA, C-H-R-I-S-T-I-N-A. THE COURT: GO AHEAD.

16 17
18 19 20

DIRECT

EXAMINATION

BY MS. MAC CARLEY: Q MISS RAMIREZ, THERE IS A WHITE BOOK IN FRONT OF

21 22 23 24 25
26

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.

I I I

27 28

DO YOU SEE A GRANT DEED WHICH CONSISTS OF TWO

PAGES THAT'S BEHIND THAT TAB MARKED NUMBER SIX?

42

1
2

A Q

YES. AND DO YOU SEE THE NAME EVELYN OF THE DOCUMENT? I DO. CHRISTINA RAMIREZ THAT IS ON CHRISTINA RAMIREZ

3
4

IN THE MIDDLE A Q YES,

5
6

ARE YOU THE EVELYN

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?

SALE A 7 SUBJECT THE Q Q A 8 9 10

11
12 13 14 15 16 PRESENT THE COURT: SURE. A
YESr

PLEASE. I AM SORRY. MR. JOSE CASTANEDA. TO

THE COURT:

CROSS-EXAMINATION, MR. CASTANEDA:

MAY I APPROACH

THE WITNESS

17 18
19 20 21 22 23 24 25 26 27 WITNESS

DO YOU HAVE ANY DOCUMENTS? MR. CASTANEDA: SHE ALREADY -THAT SHOW THIS

THE COURT: EVELYN

-- ANY DOCUMENTS RAMIREZ

CHRISTINA

RECEIVED?

(DISCUSSION OF THE HEARING

BETWBEN

COUNSEL

OUT

OF THE REPORTER.)

THE COURT: MR.

ARE THESE YES.

RECEIVED

BY EVELYN?

CASTANEDA:

ONE WAS RECEIVED. WHY DON'T YOU SHOW HRR~

28

THE COURT:

ALL RIGHT.

43

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

44

1
2

A Q A Q

AT COCO'S

ON LAKE.

ON LAKE AVENUE? YES. WAS YOUR MOTHER WITH YOU?

3
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?

YOU ARE ASKING?

Q
A Q A Q DOCUMENT BECAUSE A Q

THE DATE? IS JANUARY 14TH.

10

JANUARY YES.

11
12
13 14 15 16 17

2006. THERE WHICH WAS AN ADDITIONAL I DON'T HAVE TODAY

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

18
19 20

OKAY. WILL IT REFRESH YOUR MEMORY IF I HAD THAT IF THAT DOCUMENT WITH

21
22 23 24 25 26 27 28

DOCUMENT ME? A Q A Q INITIALS AWARE

HAS YOUR

SIGNATURE?

OTHER NO.

DOCUMENT? I DON'T. SAY. ONLY SHOW THE ARE YOU

I CAN'T

IT WAS A POWER OF ATTORNEY/ OF FELICITAS CASTANEDA AND

IN ENGLISH/

SHE DIDN'T

READ OR WRITE

ENGLISH?

45

1
2

A
Q

WAS VERY

AWARE,

YES.

HOW

DID SHE UNDERSTOOD BY HER?

FOR THAT

POWER

OF

3 , ATTORNEY 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 THE WITNESS: THE COURT:22 THE WITNESS: 23 24

TO BE SIGNED

MS. MACCARLEY:

OBJECTION.

CALLS

FOR

SPECULATION OBJECTION OBJECTION,

AS TO MS. CASTANEDA'S TO RELEVANCE. CALLS OBJECTION,

STATE

OF MIND. FOUNDATION.

I I I
I

LACKS

FOR HEARSAY. OBJECTION SUSTAINED.

THE COURT: BY MR. CASTANEDA:

Q

LET ME ASK YOU, DID YOU ASK MR. REYES ANOTHER DID DOCUMENT BESIDES THIS? ANOTHER

TO

WITHDRAW A
Q

I ASK HIM TO WITHDRAW IS NO DOCUMENT

DOCUMENT? SPECIFIC

THERE

SIGNED

ON THAT

DATE? A
Q

I STATED YOU DON'T RIGHT.

I DON'T

REMEMBER.

REMEMBER?

THE COURT:

HOW WERE THINGS OFFICE? WELL,

EXPLAINED

TO YOUR

GRANDMOTHER

IN REYES' THE WITNESS:

IT WAS ME, MY BROTHER

AND

RAY? NOTARY PAPERS. RAY WAS BELIEVE RAY YES. PUBLIC? I EXPLAINING IS THE ... THE -YES, THE THE COURT:

25
26 27 28 , SPANISH? THE COURT: WAS THAT CONVERSATION

THAT'S

HIS

IN ENGLISH

OR

46

1 ,
2 3 4 5 6 7 8 9 10 11
12

THE WITNESS:

MY GRANDMOTHER ONLY SPOKE SPANISH.

I
I

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

13 14 15 16 17 18 19 20 21

I
I

THE TITLE TO DIFFERENT PEOPLE. UNAWARE OF ENGLISH. READ ENGLISH. Q

SHE DID KNOW SOME ENGLISH.

SHE WAS THE DEFENDER OF ALL PEOPLE, YOU CAME TO

I I
I

THE RESCUE, RIGHT? MS. MACCARLEY: THE COURT: OBJECTION.

SUSTAINED.

22 23 24 25 26 27 28

I
I
I I

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 THE SIGNATURE. IS THAT YOUR WRITING?

NOT MY WRITING.

47

1
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

3
4

5
6

TRANSFERRED FROM HER ACCOUNT? A Q A I KNOW.

Q

7 8
9

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

10

11
12 13 14 15 16

LET ME ASK YOU AGAIN.

ON DECEMBER 22, 2005,

WHERE WERE YOU AT? A

I MEAN ANYWHERE CLOSE? I DON'T KNOW.

CHRISTMASTIME? THE COURT:

DID YOU RECEIVE MONEY FROM YOUR

GRANDMOTHER IN DECEMBER OF 2005? THE WITNESS: THE COURT: ZERO FIVE? IF YOU REMEMBER.

17
18 19 20

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.

DID YOU RECEIVE $25,000 FROM YOUR

21
22 23

24
25 26 27

28

48

1
2

WHO ACCOMPANIED MY GRANDMOTHER. WHO ELSE? ALICIA CASTANEDA.

ON THE TRIP?

A
Q

3
4

A
Q

5
6 7 8 9

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

10
11

SPEAK

ENGLISH. IS ABOUT?

PROBABLY

DOESN'T
Q

PROCEEDINGS

12
13 14 15 16 17

SHE UNDERSTANDS. OBJECTION, RELEVANCE. --

MS. MACCARLEY: MR. CASTANEDA: THE COURT:

THE RELEVANCY

ASK YOUR NEXT SUSTAINED.

QUESTION.

I
I I
BY MR. CASTANEDA
Q

OBJECTION

18
19 20 21 22

YOU SAID THIS MONEY.

I DON'T

KNOW

WHAT

HAPPENED.
A
Q

THIS

IS NOT MY NAME. IT'S NOT YOUR WHAT NAME.

I KNOW THAT'S

A
Q

YOU ARE ASKING. IF THIS IS YOUR WRITING?

23
24

I AM ASKING THAT'S OKAY.

A
Q

NOT MY WRITING.

25 26
27

LET ME PRESENT
I APPROXIMATELY A

TO YOU THIS, THIS

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

WHAT ABOUT THAT'S THAT THAT MY SIGNATURE. SIGNATURE?

A
Q

IS YOUR

IS MY SIGNATURE. ELSE SIGNED THE NAME?

6 7 8

A Q A

SOMEBODY YES. SOMEBODY I DON'T

9 10
11 12 13

Q A
HEART.

-- 357 -REMEMBER. I DON'T KNOW MY ACCOUNT BY

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

TO THIS ACCOUNT? MS. MACCARLEY: OBJECTION. CALLS FOR IT'S

SPECULATION. IRRELEVANT.

LACKS

FOUNDATION.

IT IS HEARSAY.

MR. CASTANEDA: THE COURT: WHAT YOU ARE ASKING.

IT IS RELEVANT,

YOUR

HONOR. SURE

IT IS CONFUSING. TRY TO REPHRASE WHAT

I AM NOT IT.

MR. CASTANEDA: FOUNDATION IS THAT

I AM TRYING WAS TAKEN

TO LAY THE TO A BANK UNDER

MS. CASTANEDA

THE IMPRESSION

SHE WAS GOING

TO MAKE AN INVESTMENT. KNOW WHAT US. HER IMPRESSION

THE COURT: WAS, BECAUSE SHE'S

WE DON'T

28

NOT HERE

TO TELL

50