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GC 042105 Ramirez v. Castaneda Part 1 R-T 2-22-10 Trial Transcripts Re SOA - ''Counsel For Plaintiff Indicates She Had Not Received It, The Court Had Not Received It,''
GC 042105 Ramirez v. Castaneda Part 1 R-T 2-22-10 Trial Transcripts Re SOA - ''Counsel For Plaintiff Indicates She Had Not Received It, The Court Had Not Received It,''
EVELYN RAMIREZ, PLAINTIFF/PETITIONER, VS. JOSE CASTANEDA, DEFENDANT/RESPONDENT. APPEAL FROM THE SUPERIOR COURT OF LOS ANGELES COUNTY HONORABLE JOSEPH F. DE VANON, JUDGE PRESIDING TRANSCRIPT OF PROCEEDINGS FEBRUARY 22, 2010 NO. GC 042105
APPEARANCES: FOR THE PLAINTIFF: LISA MACCARLEY ATTORNEY AT LAW 3436 N. VERDUGO ROAD GLENDALE, CALIFORNIA 91208 IN PROPRIA PERSONA JOSE CASTANEDA 1377 RUTAN ROAD PASADENA, CALIFORNIA OFFICIAL REPORTER
91104
TITLE, CERTIFICATE,
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SUPERIOR
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APPEARANCES: FOR THE PLAINTIFF: LISA MACCARLEY ATTORNEY AT LAW 3436 N. VERDUGO ROAD GLENDALE ( CALIFORNIA 91208 IN PROPRIA PERSONA JOSE CASTANEDA 1377 RUTAN WAY PASADENA ( CALIFORNIA
91104
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MAS
T E R I N D E X
22{ 2010 WITNESSES WITNESSES:
FEBRUARY
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CHRONOLOGICAL PLAINTIFF'S
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CROSS 16
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REDIRECT
RECROSS
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DEFENSE WITNESS:
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CASTANEDA { ALICIA
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ALPHABETICAL
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PLAINTIFFS'
EXHIBITS IN EVIDENCE
FOR IDENTIFICATION 10
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2 CASE NUMBER: CASE NAME: GC 042105 EVELYN RAMIREZ VS.
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FEBRUARY
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2010 JUDGE
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F. DE VANONf
P. BOYERf
CSR #4329
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(AS HERETOFORE
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MR. NIGOGHOSIAN'S ATTEMPT TO CONTACT THE ATTORNEY HAD BEEN UNFRUITFUL. MR. CASTANEDA: CONTACT MR. COUNTS. THE COURT: MR. COUNTS? EMAH COUNTS. E-M-A-H, I HAVE ALSO BEEN TRYING TO
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MONTH AND I HAVE A CONTRACT, AN ATTORNEY/CLIENT AGREEMENT. AND WE AGREE HE WAS GOING TO FILE A
CROSS-COMPLAINT AGAINST DEFENDANT -- I MEAN AGAINST PLAINTIFFS FOR QUIET TITLE AND FRAUD. HE HAS SOME OF
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ATTORNEY ON ALL THE -- I I AM INFORMED NOTHING HAS BEEN ME. AND IN THE 19TH AND FAXED HIM THE SUBSTITUTION OF PRESENTED TO. LET ME JUST FIRST SAY THAT EARLIER LAST YEAR I MET, JUNE OR JULY IN DEPARTMENT -- I AM SORRY. DEPARTMENT ROOM 109. NOT
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WE WERE GOING TO MEDIATE ALL THE PAPERWORK WITH THE OTHER WE SUBMIT THIS MATTER. ATTORNEY WITH THE LAW FIRM MISS ROSAN DEROSA (PHONETIC) . YOU KNOW, I WAS AND THEY
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I FIRMLY BELIEVE THAT THEY ARE GOOD AFFIRMATIVE ACTIONS TO DEFENSE. THE COURT: AFFIRMATIVE DEFENSES. AFFIRMATIVE DEFENSES, CORRECT.
MR. CASTANEDA:
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UP TODAY.
ALSO I WAS EXPECTING MR. RAY REYES TO SHOW HE HAS BEEN A BIT SICK. I DO FEEL I WOULD LIKE THE COURT TO GRANT ME A JURY TRIAL IN THIS MATTER. NOWHERE. THE HOUSE IS NOT GOING
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SUPPOSED TO FOR A HUNDRED TO WHAT HAPPENED TO IT. AND IS INVESTMENT INFORM US AS THOUSAND DOLLARS THAT CHASE I WAS MORE THAN GLAD TO NEGOTIATE THAT WITH THEM WITHOUT HAVING TO EXPEND ALL THOSE RESOURCES. I ALSO FILED A RELATED MATTER REGARDING THE
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THE PLAINTIFF'S MOTHER IAND THE COURT: DON'T KNOW ANYTHING ABOUT A
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HAVE NOT RELATED CASE. I DO HAVE A NOTICE OF BEEN ADVISED OF ANY RELATED
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NUMBER OF TRIAL DOCUMENTS THAT YOU FILED, MR. CASTANEDA INCLUDING A WITNESS LIST AND AN EXHIBIT LIST. MR. CASTANEDA: NEED TO INCLUDE EVERYBODY. THE COURT: TO WHAT? TO INCLUDE EVERYBODY. WHICH CAN BE CHANGED. WE DON'T
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INDICATING WHO YOU EXPECTED TO CALL AT TRIAL. MR. CASTANEDA: THE COURT: CORRECT.
-- YOUR NOTICES.
I JUST DON'T KNOW WHAT TO DO WITH THIS ATTORNEY YOU SAY YOU HAVE RETAINED, WHO HAS NOT APPEARED. MR. CASTANEDA: AHOLD OF HIM. THE COURT: COMING. MR. CASTANEDA: THE COURT: I BELIEVE SO. I DON'T KNOW WHEN HE WAS PLANNING ON I HAVE NOT BEEN ABLE TO GET
ON ANNOUNCING HE WAS READY FOR TRIAL OR TO CONTINUE THE TRIAL. HE IS NOT COUNSEL OF RECORD AND HE HAS NOT HAD ANY
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THE COURT:
MACCARLEY, I AM SURE YOU ARE, THAT IF THE COURT GOES FORWARD TODAY'S DATEt WHICH WOULD BE MY INCLINATION TO DO
WHATEVER ADVERSE FINDINGS OR DECISIONS WERE MADE IN THIS CASE THAT COME OUT AGAINST HIM. I DON'T KNOW HOW THE COURT OF APPEALS WOULD REVIEW OR CONSIDER MR. CASTANEDA'S CLAIM THAT HE HAS HIRED AN ATTORNEY WHO HAS NOT COME TO REPRESENT HIM.
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MS. MACCARLEY:
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3 I HERE THIS AFTERNOON, OR BE HERE TOMORROW MORNING, I CAN 4 I TRAIL THE CASE FOR THAT PURPOSE. 5 6 7 8 9 10 11
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CONTINUE THE CASE. MR. CASTANEDA: CAN WE DO THAT? YOUR HONOR -IS IT POSSIBLE?
WE ALREADY CONTINUED TRIAL ONCE. -- WE CONTINUED THE TRIAL ONCE. VERY STRAIGHT
MS. MACCARLEY:
THIS CASE HAS BEEN FILED OVER A YEAR AGO. FORWARD MATTER.
MAIL.
I HAVE E-MAIL.
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HUMAN BEINGS ON THE FACE OF THE PLANET TO GET AHOLD OF. I LIVE AND WORK IN GLENDALE.
15 I THINK IF THERE 5 ANY ATTEMPT BY COUNSEL 16 I TO SO MUCH AS CALL ME AS LATE AS WAS O'CLOCK ON FRIDAY,
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THERE IS NOBODY HERE EXCEPT MR. CASTANEDA. HE'S HAD TWO OR THREE ATTORNEYS ALREADY IN THIS CASE, HAVE
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AM NOT WORRIED ABOUT THINK WE ARE READY APPEALS DOES. I IAM COME IN AND OUT. I WHAT THE COURT OF TO GO FORWARD. SURE THE COURT WILL DO A FINE JOB. THE COURT: YES, SIR. I DON'T BELIEVE THERE HAS BEEN THERE HAS BEEN TWO.
MR. CASTANEDA:
MR. PRATT, WHICH HE FILED A CASE FOR FRAUD AND QUIET TITLE
AND CONVERSION.
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ALSO
SLIPS
SISTER(
RAMIREZ. I HAVE
THAT
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PROOF COUPLE
WERE TAKEN
THE MONTH
TRANSFER
EVIDENCE
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THROUGH TO.
MY MOTHER
WAS DECEIVED
LET'S
NOT ARGUE
THE MERITS
OF THE IS
WE TRYING TO TRIAL
TO DECIDE TO TRIAL(
WHETHER
THE CASE
TO PROCEED
IS READY
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TO GO TO TRIAL
YOU[ VERY
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ATTORNEY
HAS THOSE RECORDS. I DON'T MR. CASTANEDA: THE COURT: ALL RIGHT(
MY WE'LL
SUPPLIED
DURING
OF THE TRIAL. MS. MACCARLEY: YOUR HONOR[ RECORDS. THERE WAS A MOTION
TO COMPEL
ME TO PRODUCE
I DID FILE AN
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YES(
TRIAL
THE RECORDS
ARE
IRRELEVANT.
ALSO
I AM
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AN ATTORNEY OF RECORD FOR MISTER -- MISS RAMIREZ AND MR. CASTANEDA. AND I WOULD ASK THAT THE OPPOSITION TO THE THERE HAVE BEEN NO ATTEMPT IN
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ANY TRUE DISCOVERY REQUESTS FOR PRODUCTION, I WOULD HAVE PRODUCED, BUT TO FILE A MOTION TO BE SET HEARD TWO WEEKS AFTER THE ORIGINAL TRIAL DATE IS TOO LITTLE, TOO LATE. THE COURT: MR. CASTANEDA. WELL, AGAIN, I DON'T HAVE ANY
MR. CASTANEDA:
DOCUMENTS TO PRESENT A FAIR DEFENSE IN THIS MATTER. THE COURT: THE MOTION TO COMPEL WILL BE DENIED. FIRST OF WHICH THE
MOTION WAS BROUGHT IN AN UNTIMELY FASHION. SECOND OF WHICH MANY OF THE INDIVIDUALS SUBJECT TO THE MOTION TO COMPEL ARE NON PARTIES TO THE PRESENT PROCEEDINGS. ADDITIONALLY, DOES NOT APPEAR TO BE A
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THE COURT:
PROPERTY.
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MS. MACCARLEY:
FELICITAS(PHONETIC) CASTANEDA
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AND IN 2006 FELICITAS CASTANEDA AND HER SON GONZALO CASTANEDA TRANSFERRED TITLE TO HERSELF FELICITAS CASTANEDA TO EVELYN CHRISTINA RAMIREZ, MY CLIENT, A PLAINTIFF, AND UPON ALONSO MANUEL CASTANEDA, ALL AS JOINT TENANTS. IN JULY -- I AM SORRY -- IN JANUARY 2008 MISS CASTANEDA SEVERED THE JOINT TENANCY AND TRANSFERRED HER INTERESTS TO JOSE CASTANEDA. VERY STRAIGHT FORWARD MATTER. THE THREE
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NAMES ON TITLE ARE EVELYN, CHRISTINA RAMIREZ, ALONSO EMANUEL CASTANEDA AND JOSE CASTANEDA. THE COURT: THE PLAINTIFF'S POSITION IS THAT
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EACH NAMED PARTY HAS ONE-THIRD UNDIVIDED INTEREST IN THE PROPERTY? MS. MACCARLEY: THE COURT: CORRECT, YOUR HONOR.
MS. MACCARLEY:
POSSESSION, DO NOT HAVE ANY RENT BEING PAID TO THEM WHICH THEY ARE NOT CLAIMING FOR REIMBURSEMENT, THEY ARE SEEKING A PARTITION BY SALE.
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DECLARATION. RECEIVER NAMED WE HAVE OBTAINED CONSENT .BYAND REFEREE AND LEON J. OWENS (PHONETIC) A THAT'S BEEN SUBMITTED AND HE WOULD LIST THE PROPERTY FOR SALE AND COMPLETE THE SALE, AND DIVIDE THE RESPECTIVE INTERESTS
THE COURT:
THANK YOU.
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MR. CASTANEDA, YOU WISH TO MAKE AN OPENING STATEMENT NOW OR SAVE IT UNTIL YOU START THE DEFENSE CASE? WHAT IS YOUR REFERENCE? MR. CASTANEDA: WELL, AGAIN, I AM NOT PREPARED
TO PROCEED WITH THIS TRIAL, AND I WAS EXPECTING MR. COUNTS TO BE HERE TODAY. THE COURT: I AM SORRY MR. COUNTS HAS
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DISAPPOINTED YOU, BUT THE CASE HAS ALREADY PREVIOUSLY BEEN CONTINUED FOR TRIAL. I CAN'T JUSTIFY CONTINUING IT ON THE
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BELIEF A LAWYER MAY COME IN ON SOME FUTURE DATE. FIRST WITNESS, MISS MACCARLEY.
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FOR THE TRIER OF FACT. THE COURT: HAND THOSE TO THE COURT.
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THE COURT MS. ADMIT INTO EVIDENCE, WOULD LIKE TO DO IS ASK TO MACCARLEY: WHAT I SUBJECT TO ANY OBJECTIONS BY COUNSEL, THE CHAIN OF TITLE RECORDS, EXHIBIT MARKED AS PLAINTIFF'S EXHIBIT NUMBER ONE. THE COURT: ONE IS THE GRANT DEED. THIS IS A DEED IN WHICH GONZALO
MS. MACCARLEY:
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AND MARTHA CASTANEDA BECAME JOINT TENANTS OF THE PROPERTY. THAT'S THE FIRST TIME THAT MRS. CASTANEDA WAS ON RECORD. THE COURT: THAT'S THE GRANT DEED. THE COURT
HAS A CERTIFIED COPY OF THAT. MS. MACCARLEY: NUMBER 98639900. THE COURT: ONE. IT WILL BE RECEIVED AS PLAINTIFF'S YES. DOCUMENT -- INSTRUMENT
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MS. MACCARLEY:
THANK YOU.
PLAINTIFF'S MARKED EXHIBIT 2 IS A DEED DATED JULY 3RD, 2000, IN WHICH GONZALO CASTANEDA AND
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MARTHA C. CASTANEDA AND FELICITAS CASTANEDA -- I AM SORRY. WHERE MARTHA CASTANEDA NOW/ QUIT CLAIMS HER INTEREST. SO
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EXECUTED -- LOOKS LIKE IT WAS SIGNED SEPTEMBER 15. THE COURT: EXECUTED 9/15 AND RECORDED JULY 3RD.
THE COURT HAS A CERTIFIED COPY OF THAT AS WELL. MS. MACCARLEY: THANK YOU. AND CAN IT BE
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MS. MACCARLEY:
THANK YOU.
PLAINTIFF'S 3 IS A GRANT DEED FROM GONZALO CASTANEDA AND MARTHA C. CASTANEDA AND FELICITAS CASTANEDA, NOW VESTING TITLE TO FELICITAS CASTANEDA. THAT
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(PLAINTIFF'S EXHIBIT 3 WAS MARKED FOR IDENTIFICATION: 2001.) GRANT DEED MAY 30,
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MS. MACCARLEY:
THANK YOU.
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AND EXHIBIT FOUR IS A GRANT DEED EXECUTED ON SEPTEMBER 26, 2005, IN WHICH GONZALO CASTANEDA -- I AM SORRY -- FELICITAS CASTANEDA GRANTS TO GONZALO CASTANEDA AND FELICITASS CASTANEDA AS JOINT TENANTS, THE SAME
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NUMBER 052421819 AND ASK THE COURT FOUR WILL BE RECEIVED THE COURT: PLAINTIFFIS --
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INTO EVIDENCE.
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MS. MACCARLEY:
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FELICITAS CASTANEDA. BANK, AND WAS RECORDED THE OCTOBER IS WASHINGTON INSTRUMENT ON LENDER 7, 2005, AS MUTUAL NUMBER 052421821. THE COURT: I AM SORRY. PLAINTIFF'S FIVE WILL
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MS. MACCARLEY:
FROM FELICITAS CASTANEDA AND GONZALO CASTANEDA GRANTING TITLE TO FELICITAS EVELYN CASTANEDA, EVELYN CHRISTINA
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MS. MACCARLEY:
I AM SORRY.
JANUARY 14TH, I
APOLOGIZE, 2006.
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THE COURT:
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MS. MACCARLEY:
AND THEN FINALLY PLAINTIFF'S SEVEN IS A DEED FROM FELICITAS CASTANEDA TO JOSE CASTANEDA EXECUTED ON JANUARY -- LOOKS LIKE 28TH OR 29TH, 2008 WAS RECORDED
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MS. MACCARLEY:
THERE WAS A STIPULATION THAT PLAINTIFFS DO NOT OBJECT OR PROTEST THE LOAN OBTAINED BY MRS. CASTANEDA AND JOSE -GONZALO CASTANEDA. AND THAT WELLS FARGO BANK SUCCESSOR
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NOW J. P. MORGAN CHASE BANK WOULD BE PAID THROUGH ANY ESCROW. AND THAT THEIR INTERESTS ARE SUBJECT TO THE LOAN
AND ENCUMBRANCE ON THE PROPERTY. THE COURT: NOTE THAT AS PLAINTIFF'S EIGHT. YES.
MS. MACCARLEY:
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STIPULATION.)
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(PAUSE.)
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THE MACCARLEY: IYOUR FIRST WITNESS. ALONSO, MS. COURT: CALL WOULD LIKE TO CALL A-L-O-N-S-O, CASTANEDA. THE COURT: FORWARD BE SWORN. MR. CASTANEDA, ASK YOU TO STEP
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ALONSO CASTANEDA,
CALLED AS A WITNESS ON BEHALF OF THE PLAINTIFF, WAS DULY SWORN AND TESTIFIED AS FOLLOWS:
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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
TRUTH, SO HELP YOU GOD. THE WITNESS: C-A-S-T-A-N-E-D-A. ALONSO CASTANEDA. A-L-O-N-S-O,
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DIRECT
EXAMINATION
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BY MS. MACCARLEY: Q CASTANEDA? A SHE IS MY GRANDMOTHER. AND I PUT IN FRONT OF YOU AN EXHIBIT BOOK, AND I WHAT IS YOUR RELATIONSHIP TO FELICITAS
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NAMED IN THAT GRANT DEED? A Q YES, I AM. AND WHEN DID YOU FIND OUT THAT YOU HAD BEEN
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NOT --
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2S
A DOCUMENT.
I DID NOT PREPARE THE PREPARATION OF THE I BELIEVE I WAS THERE TO SIGN THIS DOCUMENT. I DID NOT SIGN
THIS IS A GRANT DEED -- I AM SORRY, NO. THIS DOCUMENT. Q OKAY. I BELIEVE REYES DID.
PROPERTY SOLD THAT IS THE SUBJECT OF THIS LAWSUIT WHICH YOU OWN NOW? A Q SALE?
A
YES.
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YES,
I HAVE.
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HAS HE REFUSED TO PARTICIPATE IN THE SALE? YES( HE HAS. MR. CASTANEDA: OBJECTION( YOUR HONOR. AM I
ALLOWED TO OBJECT TO THAT? THE COURT: WHAT IS THE BASIS? MR. CASTANEDA: THE COURT: OBJECTION TO THAT? MS. MACCARLEY: ALL RIGHT. NO FURTHER I WAS NEVER CONTACTED BY -THE YOU CAN OBJECT TO ANYTHING YOU WANT.
CROSS-EXAMINATION
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BY MR. CASTANEDA:
Q
MR. CASTANEDA ( WHEN IS IT YOU CONTACTED ME TO CAN YOU GIVE ME A SPECIFIC DATE?
I CANNOT REMEMBER THE SPECIFIC DATE. THE YEAR PERHAPS? THE COURT: CAN YOU TELL US APPROXIMATELY WHEN
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LAST 2009?
YEAR.
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THE WITNESS: BY MR. CASTANEDA: Q A PHONE. MS. MACCARLEY: THE TAKE IT DOWN COURT: WHEN THROUGH PHONE?
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THROUGH
A LETTER? BY PHONE. BY
I BELIEVE
I TRIED
TO CONTACT
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HIM ANSWER
BEFORE
QUESTION.
BY MR. CASTANEDA: Q A DO YOU KNOW WHAT YEAR IT WAS YOU SAY? YES, 2009.
2009.
YOU SAID WHAT MONTH?
A Q CELL PHONE
NO,
I DID NOT. NO IDEA WHAT MONTH. FOR THAT, RIGHT? ARGUMENTATIVE, SO SHOULD BE SOME
OBJECT.
THE COURT:
DO YOU KNOW OF ANY PHONE THE WITNESS: THE COURT: THE WITNESS: BY MR. CASTANEDA: Q SO, YOU PROBABLY KNOW MY PHONE NO, I DO NOT. -- VERIFY NO.
A TELEPHONE
CALL?
I CALLED
FROM MY CELLPHONE.
NUMBER.
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Q
MR. CASTANEDA: THE COURT: GET THE NUMBER? THE WITNESS: THE COURT:
SHE HAS JUST -THE WITNESS: I SPOKE WITH ALL THE RELATIVES,
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MAKING UP THE STORY ABOUT CONTACTING ME. MS. MACCARLEY: THE COURT: OBJECTION.
AROUND TO THAT SIDE OF THE CASE. MR. CASTANEDA: THE COURT: YES. I DON'T HAVE ANY EXHIBITS TO CAN MAY I PLEASE ASK A QUESTION?
THIS BE ALLOWED TO BE REPRESENTED? THE COURT: I DON'T KNOW WHAT IT IS, SIR. IT'S A CHECK FOR $200 FROM
MR. CASTANEDA:
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FELICITAS CAST~~~pA, ACCOUNT PAYABLE TO HIM, AND T~_~RE IS THIS IS FROM -- AGAIN,
THIS IS SOME OF THE EXHIBITS I HAVE WITH ME, I WAS GOING TO PROVIDE TO MY ATTORNEY. THE COURT: WHAT'S THE RELEVANCE OF THE CHECKS? THAT HE RECEIVED MONEY FROM MY
MR. CASTANEDA:
MOTHER MANY TIMES AND THAT AGAIN WHEN HE -- WHEN THEY TOOK MY MOTHER TO MR. REYES' OFFICE SHE WAS UNDER THE IMPRESSION THAT SHE COULDN'T HAVE ANY MONEY OR PROPERTY ON HER NAME BECAUSE HER BENEFITS HAD BEEN CANCELED. SO, IT WAS THROUGH FRAUD AND TRICKERY THEY BROUGHT MY MOTHER TO MR. REYES' HOME -- I MEAN OFFICE. AND I THINK MR. REYES WILL CONFIRM THAT, AND THAT HE WAS TOLD DIFFERENT THINGS HAVE FILED HIS DECLARATION ON THE RECORD. AND THATIS BASICALLY WHAT I WANTED TO -MS. MACCARLEY: WELL, YOUR HONOR, I AM OBVIOUSLY
GOING TO OBJECT AND ASK THE COURT TO PLEASE STRIKE MR. CASTANEDA'S STATEMENTS THAT HE IS NOT SWORN UNDER OATH. HE IS NOT TESTIFYING RIGHT NOW, AND I DON'T SEE THE RELEVANCE. ANY CASE. THE COURT: WELL, THE ONLY ISSUE BEFORE ME RIGHT AND MOST OF WHAT HE IS SAYING IS HEARSAY IN
NOW IS WHETHER OR NOT HE CAN ASK MR. ALONSO CASTANEDA REGARDING SOME CHECKS. RELEVANCY OF THE CHECK. MS. MACCARLEY: THE COURT: RIGHT. I STILL DON'T UNDERSTAND THE
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DON'T HAVE ANY EVIDENCE OF THAT. MR. CASTANEDA: THE COURT: OKAY.
MR. CASTANEDA:
KIDS ALL OF HER MONEY AND ALL OF HER LOVE. THE COURT: YOU WANT TO KNOW IF HE GAVE ALL HIS
MONEY TO MR. ALONSO -MR. CASTANEDA: I KNOW OUR MOTHER WAS THE ONE
THAT CONCOCTED THIS PLAN, AND PROOF OF THAT ARE ALL THE WITHDRAWALS AND THE CHECKS THAT I HAVE BEFORE ME PAYABLE TO GONZALO CASTANEDA AND FELICITAS CASTANEDA FOR GONZALO FOR $30,000 AND SUSAN CASTANEDA FOR APPROXIMATELY TOTAL OF $70,000. $40,000,
THAT I ALSO HAVE THAT TRANSFER FOR $25,000 ON NOVEMBER 22 FROM HER ACCOUNT INTO ANOTHER ACCOUNT. AND THAT ACCOUNT
SHE WAS TOLD THAT IF SHE WAS GOING TO MAKE IT INTO AN INVESTMENT. I THINK MRS. CHRISTINA KNOW WHICH INVESTMENT
AND WHERE THIS IS, INVESTMENT, RIGHT NOW FOR THAT AMOUNT. MS. MACCARLEY: MOTION TO STRIKE. AGAIN, YOUR HONOR, OBJECTION. IT'S
WHAT THE RELEVANCE IS. THE COURT: WHY DON'T YOU SHOW COUNSEL THE CHECK
SO SHE KNOWS WHAT YOU ARE -- I WILL PERMIT MR. CASTANEDA TO ASK THE WITNESS ABOUT THE CHECK SUBJECT TO A MOTION TO