Page 5
1
said here today and if you notice, she's doing that with
2
her fingers and the reason I point that out is she
3
cannot record both of us speaking at the same time, so
4
what that means for you and I is that you need to wait
5
until I finish my question before you give me your
6
answer, okay?
7
A Yeah.
8
Q In that same vein, because she is doing this
9
with her fingers, if the question calls for a yes or no
10
answer, you need to audiblize it by saying yes or no.
11
Do you understand that?
12
A Yes.
13
Q The reason is because a nod of the head, a
14
shake of the head, an "uh-huh" or "huh-uh" will not come
15
out clear on the transcript. Do you understand that?
16
A Yes.
17
Q I'm not here today to try to trick you with my
18
questions. However, if you do answer the question, it
19
will be assumed that you understood the question, okay?
20
A Yes.
21
Q If you don't understand the question, please
22
tell me you don't understand the question and I'll ask
23
it again, I'll rephrase it, I'll break it down into
24
smaller parts or whatever it takes to facilitate your
25
understanding, okay?
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1
A Yes.
2
Q During the course of this deposition, if you
3
need to take a break, you're welcome to. The only thing
4
I ask is if there's a question pending, that you finish
5
answering the question, all right?
6
A Okay.
7
Q At the conclusion of this deposition, the court
8
reporter is going to take down everything that was said
9
here today and transcribe it and put it into a booklet
10
called a transcript. Do you understand that?
11
A Yes.
12
Q After this transcript is put together, you'll
13
be given an opportunity to review the transcript should
14
you so desire. Do you understand that?
15
A Yes.
16
Q You'll also be given the opportunity to make
17
changes to the transcript if you so desire as well. Do
18
you understand that?
19
A Yes.
20
Q I need to caution you, however, if you do make
21
changes to the transcript of a substantive nature, I
22
will be able to comment upon it at any trial,
23
arbitration, evidentiary hearing or motion practice as
24
the case may be. Do you understand that?
25
A Yes.
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Q When I say comment upon it, what I mean is I'll
2
be able to bring your credibility into question. Do you
3
understand that?
4
A Yes.
5
Q If you testify differently at any trial,
6
arbitration, evidentiary hearing than you do today, I
7
will also be able to comment upon it as well. Do you
8
understand that?
9
A Yes.
10
Q Again, when I say comment upon it, what I mean
11
is I'll be able to bring your credibility into question.
12
Do you understand that?
13
A Yes.
14
Q I always have to ask these for the record, are
15
you on any type of medication today that would affect
16
your ability to understand my questions or answer them
17
accurately?
18
A No.
19
Q And I've already asked you this in previous
20
depos, but just for the purposes of this deposition,
21
have you ever been convicted of a felony?
22
A No.
23
Q Have you ever been convicted of a misdemeanor
24
that involves fraud, theft or dishonesty?
25
A No.
Kenner v. Antinoro, et alGerald AntinoroPage 2 (5 - 8)
Bonanza Reporting & Videoconference Center(775) 786-76551111 Forest Street Reno, NV 89509Page 8
1
Q And I know I've taken your depo before, but
2
these are two separate cases, so you're going to have to
3
bear with me while I go through your background again
4
and I know it's already in another transcript. What is
5
your level of education?
6
A I have two master's degrees.
7
Q Let's start -- obviously before you had a
8
master's degree, you had to have a B.S.?
9
A Yes, I have a bachelor's degree.
10
Q In what?
11
A Organizational management.
12
Q Where did you get your degree from?
13
A Ashford University.
14
Q Ashford University is located where?
15
A In Clinton, Iowa.
16
Q Was that an on-line course?
17
A Yes.
18
Q What year did you get the degree?
19
A I think it was around 2009.
20
Q Where were you located when you got the degree?
21
A Virginia City.
22
Q And you got a master's degree from where? Two
23
master's degree, let's start with the first one.
24
A One was from Ashford University.
25
Q In what field?