155 157

1 back from the remodel -- from the 1 A. The debt, yes.

2 remodel? 2 Q. And that would be the only debt that
3 A. Of the -- somewhere -- I had given 3 you know that you guys have?
4 him from that 4 A. Yes. I paid off all the other credit
5 Q. Correct. But what I am saying is you 5 cards.

6 had coming into you at this point 6 Q. Okay.

7$ 7 MR. BALDWIN: I have no further questions.
8 A. No. 8 THE COURT: Any redirect, Ms. Stern?
9 from the land. I didn' t -- 9 MS. STERN: Just briefly.
10 Q. Okay. That is my misunderstanding? 10
11 A. Yeah. That money had come from the 11 REDIRECT EXAMINATION
12 land. I start remodelling, paying them, but when 12 MS. STERN:

13 Saeed got out I received it back. 13 Q. Is it your testimony that this should
14 Q. Okay. 14 be split with the exception of your attorney fees?
15 A. So it wasn' t 15 A. Correct.

16 16 Q. So to the extent that there is a charge

17 Q. Okay. And then if you can go to, I 17 to my office on, it looks like 12- 16, in the
18 think it is Exhibit 7. 18 amount of 2, 500?

19 A. Yes. 19 A. Correct.

20 Q. Actually, I think that' s wrong. I 20 Q. That -- is it your testimony that that

21 think my fat fingers typed the wrong numbers when 21 should be your separate debt?
22 I was doing it. I think it is Exhibit 6, I' m 22 A. Yes.

23 sorry. 23 Q. Okay. Very briefly, Naghmeh. For

24 A. Is that this miles and more? 24 clarification, you testified that -- there has

25 Q. Hold on one second. It's actually 25 been testimony that Saeed received $
156 158
1 Exhibit 5, I' m sorry. It's your Chase credit card 1 those funds that you got out of the contract,
2 account? 2 correct?

3 A. Uh- huh. 3 A. Correct.

4 Q. So on page number PE 0044 that would be 4 Q. And those were funds that were
5 your most resent statement, right? 5 initially from the property sale?
6 A. I believe the cutoff date was January 6 A. Correct.

7 something. I believe the balance is closer to 7 Q. Okay. And then he received additional
8 8500. It is a guess. But I know it is right 8 funds, did he not, for the division of the bank
9 around that. 8500, 8600. 9 account?

10 Q. Okay. And so from December 27th, which 10 A. Yes. The DL Evans Bank account. Yes.

11 is on page 01040 to the next month, you had an 11 And he received funds from -- there was an account
12 amount balance in December of about $ 3, 300. Does 12 at the church as well that I believe he received
13 that sound about right? 13 somewhere between 8- to $10, 000 on that one too.
14 A. Uh- huh. 14 Q. Okay. And that account no longer
15 Q. And then the next month it shot up to 15 exists?

16 about $ 7, 700? 16 A. No. The church split the money, paid

17 A. I' m putting all the kids cost on my 17 knowing that we
18 credit card. 18 had agreed to that, and then divided the money
19 Q. And did you put your attorney fees on 19 between Saeed and me.

20 that credit card also? 20 Q. Okay. And do you recall whether or not
21 A. Yes. There is a $ 2, 500 attorney fee as 21 the initial DL Evans Bank account split was done

22 well. 22 shortly after he was released or was there -- or

23 Q. And is it your testimony that that 23 was that later on?

24 account should be split in half or who should pay 24 A. It was. It was within days that you

25 for that account? 125 asked me what money was in what account and that
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 1 1 REDIRECT EXAMINATION

2 BY MS. STERN:

3 Q. Naghmeh, are these set up

4

5 A. I believe so.

fore 6 Q. And can

By 7

8 A. They can.
9 THE COURT: And if they
10

12 THE WITNESS: It would probably

13 I am not 100 percent sure.

14 THE COURT: Any questions as a result of my

15 questions, Mr. Baldwin? Ms. Stern?

16 MS. STERN: No, Your Honor.

17 THE COURT: Ma' am, you can step down and

18 have a seat next to your attorney.
19 THE WITNESS: Thank you.

in credit card debt, plus the house debt. 20 THE COURT: Ms. Stern, do you have

21 And over the years I was able to pay off all of 21 additional witnesses today?
22 our credit card debts as well. 22 MS. STERN: Yes, Your Honor. I would like

23 MS. STERN: Thank you. 23 to call Homy Panahi, please.

24 THE COURT: Anything else, Mr. Baldwin? 24 THE COURT: Okay.
25 MR. BALDWIN: No, Your Honor. 25 MS. STERN: I will get some more water and
nA in7/ 7n17 n7. 40- 17 DM Dano 1 SQ fn 1 F,7 of 74A 40 Of 61

r
 163 165
1 then I will get him out of the conference room. 1 hand to PE 0181.
2 THE COURT: Thank you. 2 A. PO?

3 Good afternoon. Are you Mr. Panahi? 3 Q. PE 0181.

4 THE WITNESS: Yes. 4 THE COURT: It is the last document before

5 THE COURT: Can you kindly come forward and 5 tab 18.

6 raise your right hand. I will have you sworn in 6 THE WITNESS: Yes.

7 by my clerk. 7 Q. BY MS. STERN: Mr. Panahi, do you

8 8 recognize the copy of that check?
9 HOMY PANAHI, 9 A. Yes.

10 called as a witness by and on behalf of the 10 Q. What is the date on it?

11 petitioner, having been first duly sworn, was 11 A. May 31st, 2008.
12 examined and testified as follows: 12 Q. The copy of the check is it May 30th,
13 13 2006, sir?

14 THE COURT: If you can have a seat up there 14 A. It is 2008.

15 in that green witness chair, please. Mr. Panahi, 15 MS. STERN: Your Honor, I think the record
16 Ms. Stern is going to ask you some questions. 16 can reflect that this copy actually says 2006. It

17 There is a chance that Mr. Baldwin may tinder an 17 is a poor copy.

18 objection, and if he does I just need you to stop 18 THE COURT: To clarify, sir, there is a
19 talking for a minute while we determine whether 19 check number at the top. Are you looking at check
20 you will go forward answering the question or 20 number 914233? It is at the top of the check.
21 whether we will move on. We just don' t want to 21 THE WITNESS: No. I see that. May 30th,
22 all be talking at the same time. 22 2006.

23 So after Ms. Stern asks you some 23 THE COURT: Thank you.
24 questions, Mr. Baldwin will have an opportunity to 24 THE WITNESS: Thank you.

25 follow up on that as well. 25 THE COURT: That is what Ms. Stern is

164 166
1 So Ms. Stern, when you are ready. 1 referring to and I can see that he is looking at
2 2 that.

3 DIRECT EXAMINATION 3 MS. STERN: Thank you, Your Honor.

4 BY MS. STERN: 4 Q. BY MS. STERN: Okay. Is the date on

5 Q. Sir, could you please state your full 5 that check May 30th, 2006?
6 name and spell your last name for the record? 6 A. Yes. May 30, 2006.
7 A. My name is Homy Panahi. The last name 7 Q. Okay. And do you recognize that check?
8 is P -A -N -A -H -I. 8 A. Yes.

9 Q. And where do you live? 9 Q. Do you recall who directed that check

10 A. In Boise, Idaho. 10 to be prepared?

11 11 A. My wife did.
12 THE COURT: And sir for the record, could 12 Q. And do you recall why your wife and you
13 you spell your first name too, please. 13 directed that check to be prepared?
14 THE WITNESS: H - O -M - Y. 14 A. For down payment of a house as a gift
15 THE COURT: Thank you, sir. 15 to my daughter.
16 Q. BY MS. STERN: Mr. Panahi, are you 16 Q. Okay. Was that meant to be a gift for
17 Naghmeh' s father? 17 your daughter or a gift to your daughter and her

18 A. Yes. 18 husband?

19 Q. Sir, I would like to address -- direct 19 A. Well, to my daughter. Just like my

20 your attention to that white folder in front of 20 other children.

21 you to Exhibit 17. It is marked with a little 21 Q. Have you in the past -- had you made

22 flap. 22 similar gifts to your other children?

23 A. Yes. 23 A. Yes.

24 Q. Okay. And I would like to direct your 24 Q. And what was your goal behind these
25 attention, there are numbers on the bottom right 125 gifts?

4141 OTOT blbl sheetssheets roycroyc ivyivy ww iuviuv vivi cwcw

, , , ,
 167 169

1 A. Well, the goal -- we believe in the 1 excuse him back to the conference room. I would

2 hope I don' t have to recall him. But there is a

2 family that we need to give the gifts so they
3 would have home and security. 3 small chance.

4 Q. And I will refer you to the first page 4 THE COURT: All right. Sir, you can step
5 of Exhibit 17, sir. 5 out in the conference room or be somewhere out
6 A. Okay. 6 close by where Ms. Stern can find you if needed.
7 Q. And do you see where it says on that 7 Any additional witnesses today,
8 document balance due from purchaser/ borrower? 8 Ms. Stern?

9 A. Naghmeh Panahi. 9 MS. STERN: If you can give me one minute,

10 Q. When you are looking down on that page, 10 Your Honor.

11 is there a balance due that shows what the down 11 THE COURT: Sure.

12 payment on this house would be? 12 MS. STERN: Your Honor, I have no further
13 A. Yes. It is so small. It is 13 witnesses.

14 Q. Is that the same amount of the check 14 THE COURT: Thank you, Ms. Stern. So you

15you directed to be prepared? 15 rest?

16 A. Yes. 16 MS. STERN: Yes, Your Honor.

17 Q. And is the settlement date on that 17 THE COURT: Thank you.

18 document is the date May 26th, 2006? 18 Mr. Baldwin, are you ready to begin
19 A. Yes. 19 your case?

20 Q. I would now like to direct your 20 MR. BALDWIN: Sure. We can do that, Your
21 attention to Exhibit No. 20, sir? 21 Honor.

22 A. Yes. 22 THE COURT: Who will your first witness be,

23 Q. Sir, do you recognize that check? 23 sir?

24 A. Yes. 24 MR. BALDWIN: It will be Saeed Abedini.

25 Q. And is that check on your checking 25 THE COURT: Mr. Abedini, if you can kindly
168 170
1 account? 1 come forward and raise your right hand, I will
2 A. Yes. 2 have you sworn by my clerk.
3 Q. And do you recognize that signature? 3

4 A. Yes. 4 SAEED ABEDINI,

5 Q. Whose signature is that? 5 called as a witness by and on behalf of the

6 A. My wife. 6 respondent, having been first duly sworn, was
7 Q. Do you recall this check being written? 7 examined and testified as follows:
8 A. Yeah. We discuss it. 8

9 Q. Okay. And do you recall -- and is the 9 THE COURT: Thank you, Mr. Abedini. You can

10 date on that check 6- 16- 2009? 10 have a seat in that green chair there. And you
11 A. Yes, 6- 16- 09. 11 have heard me explain to a couple of other
12 Q. Why was this check written? 12 witnesses how this process works, do you have any
13 A. For gift for buying the land. 13 questions about that?

14 Q. Okay. So was this intended as a gift 14 THE WITNESS: No.

15 to buy land for Naghmeh or Naghmeh and Saeed? 15 THE COURT: Mr. Baldwin, when you are ready.
16 A. Naghmeh only. 16 MR. BALDWIN: Thank you, Your Honor.
17 MS. STERN: I have no further questions. 17

18 THE COURT: Any cross, Mr. Baldwin? 18

19 MR. BALDWIN: No, Your Honor. 19

20 THE COURT: Sir, you can step down. Any 20

21 reason to think this witness will be needed later 21

22 today? 22

23 MS. STERN: Your Honor, there may be a 23

24 reason that he would be needed later today so I 24

25 was not going to excuse him. I would like to 25

14/ 03/ 2017 ( 12 39. 27 PM Paoe 167 to 170 of 246 42 of 61 she(
 171 173
1 DIRECT EXAMINATION 1 will stay.
2 BY MR. BALDWIN: 2 Q. But if you can' t then what will happen?

3 Q. Mr. Abedini, will you please state your 3 A. I will leave.

4 name and spell the last for the record. 4 Q. Do you have any --
5 A. Saeed Abedini, S- A, double E, D. 5 THE COURT: I couldn' t hear that last
6 A -B -E - D -I -
N -I. 6 phrase, what did you say?
7 Q. Okay. And Mr. Abedini, are you 7 THE WITNESS: I said if I can have kids
8 currently married? 8

9 A. Yes.

10 Q. And who are you married to? 10 THE COURT: Thank you, sir.
11 A. Yes. 11 Q. BY MR. BALDWIN: And you understand

12 Q. Who are you married to? 12 that

13 A. Naghmeh Abedini. 13

14 Q. And she is the petitioner in this case 14 A. Yes.

15 and you are the respondent; is that correct? 15 Q. And you understand
16 A. Yes. 16 A. I don' t accept that.
17 Q. And Mrs. Abedini testified earlier 17 Q. But you understand what his
18 today that you were married on June 30th, 2006; is 18

19 that correct? 19 A. Yes.

20 A. Yes. 20 Q. Why is it that you do not accept

21 Q. And where do you currently reside? 21

22 Where do you live? 22 A. Because of

23 A. 23 she -- he wrote and

24 24 been told.

25 Q. And how long have you been at that 25 Q. Okay. What lies has he been told?
172 174

1 address? 1 A.
2 A. One year. 2

3 Q. Is that where you came after you were 3 weapon in my whole life.
4 released from prison? 4 Q. You' ve got that binder in front of you,
5 A. Yes. 5 correct?

6 Q. Have you lived any other places since 6 A. Yes.

7 you have been released from prison? 7 Q. Why don' t you go to Exhibit No. 1. If

8 A. I was hiding in some hotels for two 8 you go to page -- you see there are page numbers

9 weeks and I forgot the name. Sun Valley because 9 on the bottom, PE 0023?
10 of the reporters and the media. 10 A. Yes.

11 Q. Okay. Did you go to Alaska this summer 11 THE COURT: On the bottom right- hand corner,

12 for a time? 12 sir. And what number were you referring to,
13 A. For a couple weeks. 13 Mr. Baldwin?

14 Q. Okay. And did you go in November to 14 MR. BALDWIN: PE 0023.

15 Virginia? 15 THE COURT: Thank you, sir.

16 A. Yes. 16 THE WITNESS: Okay.

17 Q. Okay. And what is your intentions 17 Q. BY MR. BALDWIN: If you look at the top
18 regarding staying in Boise or moving somewhere 18 of the page it says do you f

19 else? 19 see that?

20 A. lust family, kids. Being with kids. 20 A. Yes.

21 Q. Okay. 21 Q. And then there are numbers?

22 A. 22 A. Uh- huh.

23 Q. Explain to the Court what you mean by 23 Q. Are you talking about paragraph number
24 that? 24 two, I think it would be the second full sentence

25 A. If.I can 25 that starts " additionally"?

43 Ot bl sheets raye iii w lfw Ui 4Y0 .
 175 177

1 A. Yes. 1 Q. Do the
2 Q. " Mr. Abedini ? 2

3 A. Uh- huh. 3 A. I think so, yeah.

4 Q. So is your testimony that you do not 4 leave the house. --
5 5

7 Q. You have never touched weapons. You 7 are here. And

8 don' t own 8 became 7: 00 -- at 7: 00 p. m. the first month
9 A. No. 9

13 Q. Okay. Was there anything else in 13 Q. Okay. So they are asking

14

15 A. Yes.

16 A. 16 Q. What type of

17

23 that you may be moving

24 Q. So your testimony is 24

25 was actually 25 A. Yeah. The last whole year I stayed

176 178

1 A. Yes. 1 And because of the

2 Q. Let me back up and go back to where you 2 thing happened between me and Naghmeh one- and- a-
3 currently reside. Does anybody live with you? 3 half year ago. But I don' t want to open up -- I

4 A. Not at this time. 4 said if we have this chance I don' t want any
5 Q. Okay. And since your release you have 5 church members be here because I told you I cannot

6 had time to spend with your children, correct? 6 open up more because I don' t want to talk negative
7 A. Yes. 7 about her when the church members are here.

8 Q. Okay. And how often do you get to see 8 Q. You understand that this is a public

9 them? 9 forum so we can' t necessarily exclude people from

10 A. Three times each week, four hours each 10 here?

11 day. 11 A. Okay. So everyone heard on the news

12 Q. Okay. And how are those visitations 12 about how I turn to Christ, how I started largest
13 going? 13 church in Iran Christianity and as a strong Muslim
14 A. I am trying my best to 14 how I met ) esus and got born again. And when I
15

20 as like a Christian pastor with doing something

21 for preaching the gospel and So 21 amazing. And so I reject everything she said that
22 22 I am a lazy person. How I could be lazy when I
23 They 23 raised 200 pastors. And start hundred under

24 things they But I am trying 24 ground churches in 30 cities across the country.
25 my best 25 so--
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 179 181

1 Q. Let me back up. So your testimony is 1 I left the church and then I start
2 that between 2004 to 2007 or eight you were 2 orphanage and went back Iran. But during that
3 working as a pastor; is that correct? 3 time Pastor Bob was so scarred that I tell

4 A. Yes. 4 negative about him to his pastor' s in California.

5 Q. And during that time that is when you 5 THE COURT: What is his name again, sir?
6 were doing what you are explaining to the Court? 6 THE WITNESS: Bob Caldwell.

7 A. Uh- huh. 7 THE COURT: Thank you.

8 Q. Correct? 8 THE WITNESS: Pastor Bob Caldwell, Calvary
9 A. Yeah. 9 Chappal. Naghmeh' s church. She was his
10 Q. And were these churches based out of 10 secretary. So he was so scared that I say
11 Iran or here? 11 negative thing about him and he use Naghmeh
12 A. Yeah. It was all underground churches 12 against me. And that was the first time that he

13 across the country in Iran. 13 gave permission to Naghmeh to go and speak

14 Q. Okay. 14 negative things against me. Because he didn' t
15 A. So everything was there and then we 15 want her seeing me or shown or known with people.
16 started Pastor Bob, we started working. And then I 16 And since that time Naghmeh start saying negative
17 find it out Naghmeh uncle, Naghmeh' s dad and 17 thing about me.
18 Naghmeh' s pastor tried to take over the churches 18 Q. BY MR. BALDWIN: Saeed, maybe for a

19 and introduce these churches as their own churches 19 time reference is this around 2007 when that

20 to fundraising. And I know they fundraise nearly 20 incident occurred when you were charged with a

21 a million dollars. And so that make me so angry. 21 crime?

22 And I was working in the Pastor Bob 22 A. Yes. And then it was the time that we

23 church, in their pastor' s meeting going there for 23 were in home anD Pastor Bob said to me you should
24 more than a year and I got a paycheck. But I find 24 make Naghmeh cousin as a pastor that oversees all

25 out that that man has a serious spiritual problem. 25 the churches that you started. It was 100

180 182

1 And I saw corruption in the church -- 1 underground churches and I said he' s not

2 THE COURT: Can you give me a time frame, 2 qualified. But he said he has a good tie with
3 sir, so I understand what time frame you are 3 Naghmeh and Naghmeh has a good tie with Pastor
4 talking about? 4 Bob. So I knew he has a plan to bring all
5 THE WITNESS: It was like eight years ago. 5 churches under his leadership to make them Calvary
6 THE COURT: Thank you. 6 Chappal. And I couldn' t accept that because I was
7 THE WITNESS: And then I left that church 7 from Sons of God. And I tried to not let him do

8 because of the corruption and I saw that he wants 8 that, but he called Naghmeh so many times and push
9 to bring the churches that I started under Calvary 9 her to do that. So our conflict in the house
10 Chappal Boise ( inaudible). So I try to stop him 10 started.

11 to not let him do that and then he attacked me 11 And the day that I got arrested, I
12 physically in his office. Grabbed my neck, wants 12 never touch her. I never said -- even being loud
13 to punch to my face. And he always use Naghmeh to 13 to her. And she just came to the house and he

14 go and say to other people negative things about 14 force me on Skype to say to my leaders that I am
15 me. 15 going to make her cousin the pastor of the
16 Because he find out that I am saying 16 churches. And I said if I die I never do that

17 something wrong about his church, especially this 17 because he is not qualified. And Naghmeh start

18 pastor team. There was a generation missing there 18 pushing and then like a cat escaping from a dog, I
19 that I told him this is wrong. You need to bring 19 just want to escape. Because before that, you

20 all the people they can even correct you, but he 20 know, she attack me ten times physically.
21 said no. Every pastor under 30 years old. So I 21 Physically attack me. Even in Iran before Dubai,
22 said this is not going to work. I left my office 22 in Dubai and here. All you heard she started like

23 as showing my protest and his relationship with my 23 in Dubai --

24 wife always bothers me, the way he kissed her or 24 Q. Let' s go one by one. So your testimony
25 touch her. And so I couldn' t handle that. 25 is that you guys were traveling. You guys were in
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 183 185

1 Dubai, correct? 1 call the police and say someone is beating them
2 A. Uh- huh. 2 they don' t listen to you they are going to come
3 Q. Okay. And there was an incident that 3 and arrest you.

4 happened in Dubai, correct? 4 For me it was like a joke. I was like,

5 A. Right. 5 I am escaping from it and locking myself in the

6 Q. And what happened in Dubai? 6 door. If they come and arrest me -- I said okay,
7 A. In Dubai we were talking with our 7 if this is America, let it be America. I never do -
8 leaders on Skype and then I had an invitation to 8 that because I don' t believe he is qualified.

9 go to Qatar to speak in a church. And I was 9 Your pastor is trying to steal my churches. And
10 packing my suitcase and we got a conflict and she 10 she start counting, one, two, three, if you don' t
11 came and just -- she throw everything in my face 11 come out I will call police. I said do whatever
12 from my suitcase. And then she start, kind of, 12 you want to do. No one can push me to what should

13 like beating, punching to my face. And then I 13 I do or not. So she called 911 and she start like
14 just grabbed my face, but she just keep continuing 14 that oh, he' s beating me. Come save me. Help me.
15 yelling and throwing things to my face and 15 And I was like wow, she is kind of, like, really
16 punching to my face. You can' t do these things. 16 crazy. I never could believe she does that.
17 She was very controlling. 17 So she did that and still I was in

18 And so I just start counting. I said 18 office. And then police came, knocked on the door
19 God, if she does it more than 24 times this time I 19 and said open the door, sir. I was like -- I

20 am going to stop her. And she did it like 24 20 explained the whole situation the same as I am

21 punches to my face and yelling. So I grab my head 21 doing right now. I didn' t touch her. I didn' t
22 and cover it and she was just doing -- throwing 22 even yell at her. That' s a story. So they said
23 things on my head and you know punching to my 23 this is our policy we will take you to the jail
24 face. And then I was counting. One, two, three, 24 and you can say it to the Court.
25 four, five. So it became 24 and then I stop her. 25 Q. So you were ultimately arrested?
184 186

1 And so she called it as I attacked her. 1 A. Yeah. They arrested me --

2 The same happen when I came to United 2 Q. And you were charged with domestic

3 States and she said you need to explain to the 3 violence; is that correct?

4 churches that my cousin going to be the pastor. I 4 A. Yeah. They took me to jail.
5 said I don' t do that because I know Bob Caldwell 5 Q. And Naghmeh came and testified on your

6 wants to make him pastor and then remove me from 6 behalf; is that correct?

7 the leadership and make them Calvary Chappal and I
8 don' t let him to do that. I know his evil plan.
9 But Bob called. Every time he was calling him and
10 her and pushing her, Naghmeh, to do that.
11 And so she loves him, she believes him
7 A. Yeah. The day after that in the
8 morning it happens a lot between us. When she
9 gets angry she cannot control herself. And she
10 told me so many time that when I get angry I
11 cannot control myself. But after that when she

12 a lot as her pastor. But I saw this guy has a 12 sees, she start destroying me. She feels so bad
13 problem. And so he did it and then I just got my 13 about it and she came and kind of, like, knee down
14 laptop and went to my office, kind of like 14 on me, my feet, start crying. Kissing my legs
15 escaping like a cat from dog. And she came and 15 even with tears and said please forgive me I know
16 bug me, not even not letting me go to my office. 16 what I did.

17 And I knew that she does -- she wants to make it 17 So the day after that when I was in
18 like a physical conflict again as she did before. 18 jail I saw on a camera, maybe you have the records

19 So I just want to escape. And then finally I just 19 here, he came and she said to the judge that I

20 knee down and went to my office and lock the door. 20 never touch her. I never did that things so the

21 And then she came and she knocked on 21 judge let me go.

22 the door and said Saeed if you don' t say that I 22 Q. And she also wrote a letter to the
23 will call 911 and I will tell them that you beat 23 Court; is that correct?

24 me. And they are going to come and arrest you. 24 A. Yeah. Then she hired a lawyer and she

25 This is America, this is not Iran. If a woman 125 said the whole thing to the lawyer and my lawyer
nainzi7ni7 r' Ao PM vane 1R3 to 1R6 of 246 46 of 61 sheet
 187 189

1 said if the Court wants to -- wants me to come and
2 testify I will do that. That Naghmeh never --
3 didn' t say a lie. But he advised us to not say
4 the truth that she lied because it's going to be
5 recorded as a false report to the authority. And
1 lead me to work here. So I made the decision,
2 talk to Naghmeh, that is the only way I can go
3 and there is lots of Iranians there. My English
4 was very bad. There was the only place I can go
5 to start church. So I went there to start church

6 so he said I am going to make it through that you 6 and find a job. I got a job in a restaurant but I
7 don' t have any problem and Naghmeh doesn' t have 7 find out emotionally I cannot handle it because I
8 any problem because she lied to 911. So -- and 8 was far from kids and I was crying all night
9 then I didn' t know I got guilty until I got free 9 because I missed and a lot.
10 actually. 10 Q. So did you come back?
11 Q. You ended up pleading to a lesser 11 A. Yeah. I got a job -- I got a ministry
12 charge of disturbing the peace, does that sound 12 there but I saw I cannot handle that. So I came
13 correct? 13 back to Boise.
14 A. Yes. 14 Q. And then you start your ministry here?
15 Q. And then you eventually went to 15 A. And I make a decision not to be a
16 California for a few months; is that correct? 16 pastor because I knew that Bob Caldwell never let
17 A. Yeah. After that, you know, I lost 17 me do anything because one day I am going the say
18 everything as a person. I started the largest 18 it. And he is so scared still to not say these
19 church in Iran Christianity history. I saw so 19 things because I didn' t want the church members to
20 many wolves come to attack and take away from me. 20 hear. So I came back to just -- I said okay, I
21 And I was always fighting with them. And most of 21 will be babysitter in the home. Naghmeh goes to
22 them were American pastors, like her uncle, her 22 work. She says I will work for the Starks and we
23 dad and her Pastor Bob Caldwell, which we recently 23 are going to work out at PKG, my dad' s company.
24 found out he has been in affair with someone. 24 That going to be our investment so you can' t do
25 They remove him from authority of the church. 25 anything, you take care of the kids.
188 190

1 And then when I came here I was so -- 1 I was like for two years, three years I
2 and then I came here, you know, I was so busy with 2 was just like a mom. Feeding them. And so it was
3 the conference for the leaders and pastors. When I 3 one of the hardest time in my life. But I felt

4 came here I was just always fighting with these 4 like Joseph. So betrayed to the brothers because
5 things. So I lose everything about Bob Caldwell 5 I had something and everyone wants to have it.
6 did this to me and using her against me. And that 6 Because Iran was always on media so big people
7 was the first time that this conflict got worse 7 could make millions of dollars. ( Inaudible) stood

8 and worse among us. 8 owe in Texas a million dollars.

9 So Greg Glory, which is a very famous 9 And the pastors of Iran, the Sons of

10 pastor from California actually he called me, why 10 God pastor, the first day they told me. Be
11 you are not using Pastor Bob in your marriage 11 careful when you get married with this family with
12 conflict? I said he is the one that is creating 12 their money. They are going to steal your church.
13 all this problem. He attack me physically. He is 13 That was 12 years ago. Because they have a very
14 saying to my wife go and talk negative about your 14 bad history of what they did to other people. Be
15 husband in public because he is so scared I say 15 careful one day they are going to do it to you. 1

16 something. Because I was the only person and 16 said but I think Naghmeh really loves me. It is
17 pastor in the church that I don' t scare if I see 17 about her dad. It is about her uncle. I know

18 something wrong and say to people. But other 18 they are a businessman.
19 pastor they were so scared. So he knows that I am 19 Her dad was one of the guys that

20 going to say it. And so he kind of like shoot me 20 ( inaudible) when the whole revolution happened,

21 before I can shoot him. And then after that I 21 very strong Muslim. And he was like an assistant
22 lose everything. 22 with the TV government, TV in Iran. Very
23 So I was -- I knew that I was a calling 23 religious man. And then he turned to Christ. So

24 from God. I' m a pastor. So I made the decision 24 I thought he became Christian so he quite his

25 to go to California because I knew that he doesn' t 25 relationship with them. But after I got in prison
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 191 193

1 I find out he still has his relationship with 1 the work again.

2 Iranian Intelligent Police and working with Zapaul 2 Q. So when Naghmeh testified you were

3 phonetic) secretly. 3 traveling there probably around 2011, 2012, she

4 My dad saw that he was coming from 4 was correct; is that right?

5 intelligent police office accidentally in the 5 A. Yes.

6 street. So he still keep his relationship with 6 Q. And some period of time you took them,
7 Iran government to shut down what I started and 7 Naghmeh and the children, with you?

8 destroying my reputation. 8 A. Yes. Just once I think we went back to

9 Q. So let' s keep on track here. I get to 9 Iran together. Other times I was alone because it
10 ask the questions. We have been allowing you to 10 got too dangerous.

11 speak quite a bit here, but let' s try to do it in 11 Q. And then 2012, that is when you were
12 an orderly manner here. 12 arrested and put in prison; is that correct?

13 THE COURT: Mr. Abedini, I think what your 13 A. Yes.

14 attorney is saying is when he asks you a direct 14 Q. Okay. And did you actually receive a
15, question do the best you can to answer it as 15 sentence over there?

16 directly as possible. And if he wants to follow 16 A. After six months.

17 that up with some additional facts he will elicit 17 Q. After six months. And what was your

18 those from you. 18 sentence?

19 Mr. Baldwin, when you are ready. 19 A. Eight years.

20 MR. BALDWIN: Thank you. 20 Q. You were supposed to be incarcerated

21 Q. BY MR. BALDWIN: So between the period 21 for eight years?

22 of you stayed home with the 22 A. They told me for six months that I got
23 children? 23 a punishment. But after that when I went to the

24 A. Yes. 24 last court, which was just like five minutes, they
25 Q. And you cared for them as a father? 25 told me eight years.

192 194

1 A. Yes. 1 Q. Okay. And then you were put in prison,

2 Q. You helped them eat? 2 right?

3 A. I even woke up at midnight and changed 3 A. Yes.

4 them and let Naghmeh feed them, bring them to her 4 Q. And how was it that you were able to
5 room and then bring them back. So I was the mom. 5 communicate with Naghmeh?

6 Q. During this period were you also 6 A. It was really hard to find a cell phone
7 establishing your ministry? 7 there. But passing drugs in prison you could buy
8 A. No. Because of what Bob Caldwell and 8 cell phone. And so I had so many friends that
9 her parents and her family did to me. My 9 they were working as a spy for America, they were
10 connection was completely cut with the leaders in 10 part of CIA, they knew how I could get cell phone.
11 Iran. So we start working to build up Saeed 11 I spent like maybe $ 1, 000 to buy cell phones. And
12 Ministries, all the paperwork -- 12 the reason I just want to get cell phone, the
13 Q. When you say we, who is we? 13 first time that I knew that we have a smart watch.
14 A. Me and Naghmeh. 14 So I went to hospital and my dad gave me a smart
15 Q. You and Naghmeh? 15 watch to one of the nurse. She gave it to me and I
16 A. Yep. 16 put it in my underwear so I pass it to prison. So
17 Q. And then you started doing that; is 17 the reason was just -- I risk my life if they find
18 that correct? 18 out. They could kill me because of that. Because
19 A. Yes, Saeed Ministries. 19 of spying inside the prison. Because it was
20 Q. And is that when you started traveling 20 intelligent police prison. But the only -- the
21 over to Iran? 21 main reason I did it was I wanted to encourage

22 A. Yes. Started going back to start 22 Naghmeh and kids.

23 orphanage and visiting the leaders there. And I 23 Q. You gave Naghmeh power of attorney; is
24 went to England and Germany to speak to some 24 that correct?

25 churches and then go to Iran. So I got busy with 125 A. Yes, I did.
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 195 197

1 Q. And was that right after you were 1 children, your money, everything. And you are
2 incarcerated? 2 going to be completely destroyed.
3 A. No. I think one or two months I was 3 When she said that I was like -- I am a
4 kind of like home arrested. They told me just stay 4 Sons of God pastor, so very charismatic pastor.
5 in your home we are going to come after you. And 5 But she was in Calvary Chappal. She never said
6 so I was on home arrest. And I told Naghmeh this 6 these things. It seemed so weird to me.

7 time, I am probably going to be arrested or they 7 Q. When did that happen?

8 are going to kill me. And before I go to prison I 8 A. It was like a week before she released
9 choose my lawyer and I told to Naghmeh how she can 9 that statement on media, one -and -a - half year ago.
10 get to Fox News. 10 So I said Naghmeh, I don' t think this is from God.

11 Jay Sekulow, I choose him as a lawyer. 11 I don' t feel peace in my heart and this is not
12 So I told her that if I got arrested this time 12 from God. This is from Satan. So I say that.
13 because they warned me so many times, he is going 13 Naghmeh, it is not from God. And she said no, who
14 to be my lawyer and this is the way that you can 14 are you to tell me that. I said this is biblical.
15 get on Fox News to help me out. And so a week 15 The bible doesn' t let you speak like that. I am

16 before that Naghmeh called me and said Jay Sekulow 16 the head of the family. I am your husband.
17 said to me I need to have full power of attorney. 17 And she said no, you are public figure

18 And because that case going to be so big with the 18 the whole world is looking at you, 700 million
19 government and UN and parliaments, so I need your 19 people read your last letter from prison. So you
20 full power of attorney. I was like full power of 20 need to change your sermon and your preaching.
21 attorney? 21 Even when you talk to the feminism they listen to
22 I know you pass stock to your dad and 22 you. And I said I don' t care about feminism. I

23 you are trying to get back things because we have 23 don' t care if they don' t listen to me. And she
24 conflict for several years. So I didn' t feel good 24 said no, don' t talk to me. This is from God, you

25 about it, but I was like if Jay Sekulow said and 25 are abusing me. That was the first time she used
196 198

1 because it is going to be so big probably she 1 the word of abuse on me. And I said no, Naghmeh,

2 needs that full power of attorney. 2 this is not abusing. I am trying to correct you.
3 Q. So you gave her full power of attorney? 3 And she said don' t talk to me, I told you, I

4 A. Yes. And then when I came back and I 4 warned you if you don' t listen you are going to
5 asked Jay Sekulow and he said no, I never asked 5 lose your money, your kids, your reputation, your
6 for full power of attorney. 6 wife, everything. And I said no, this is not me.
7 Q. Okay. And you had communication with 7 I never follow you.

8 Naghmeh when you were in prison? 8 Q. So is that when you stopped

9 A. Yes, every day. 9 communicating with her?

10 Q. Okay. Did you discuss when you were in 10 A. She said after that don' t talk to me,
11 prison selling this property in Eagle? 11 you are abusing me, until you come out of prison.
12 A. Everything was good and everything that 12 So I just sent messages, text messages. Actually
13 was happening I was leading from inside the 13 I thought she got period. When she got period she

14 prison. As I said, who is going to be my lawyer? 14 always attacked me physically. Got so angry. I
15 How she can get to Fox News? Every report that 15 thought maybe she got period. She is doing things
16 comes out and everything was good until one night 16 that she doesn' t understand what she says. And

17 she came and said -- like, I think, one -and -a - half 17 maybe after a week she is going to get better. I
18 years ago she came and said, Saeed, one night I 18 waited and after a week she released that

19 was praying and a strong prisons of Lord came on 19 statement.

20 me and Lord spoke to me that God is rejecting you 20 And I found out from the prisoners, the

21 and you are not in my head anymore and Jesus 21 other prisoners, oh, your wife killed your

22 Christ is my head. And everything that I say you 22 reputation. And so I look at my cell phone and I
23 should obey. And if you don' t do that I have a 23 was like why? That is true, it is on CNN. And
24 prophesy that God is going to take away everything 24 then five minutes after that she sent a text

25 from you, your reputation, your wife, your 125 messages on Skype and she said I told you. I
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 199 201

1 killed you. You never can start on your feet. I 1 Q. And my question is, do you know of
2 killed Saeed Ministries. Bye. That was the last 2 anything that is not on this list that may be in
3 word I heard from her when I was in prison. 3 her possession that you think you need to get back

4 Q. And so when you were ultimately 4 in the divorce?

5 released is it true then that you didn' t contact 5 A. Nothing comes to my mind now.
6 her right away? 6 Q. Okay. So you generally you would agree
7 A. No. The last contact was on the phone. 7 with the division of this property?
8 She just said I gave the stock to my dad. I am 8 A. I think so.

9 going to sell the land. And I am going to empty 9 Q. And when you two were married there was

10 the account. When you come out you don' t get 10 a house that was bought. I think we had been

11 anything. And that was the last thing. And then 11 referring to it has the property?
12 when I came to Germany she called me and she was 12 A. Uh- huh.

13 like why, you didn' t tell me that you were out? I 13 Q. And what was your understanding of the
14 was like, do you know what you did to me, Naghmeh? 14 money that was given for Naghmeh' s parents?
15 That was worse than what your uncle did to me. 15 A. Her dad says I am going -- after we got

16 And then she cut the phone. And then after that 16 married he said it is going to be a gift to you to
17 she never call me. She never talked to me. She 17 buy you a house, both of you. Now he changed his
18 never even text. 18 word to his daughter. But he said the first time
19 Q. So did she ever talk to you further 19 that it is a gift for both of you.

20 about selling the property? 20 Q. But would you agree that that house
21 A. After prison time we never talk about 21 should be sold?

22 this problem. She never talks to me. 22 A. Yes.

23 THE COURT: I think the question was about 23 Q. And the proceeds be split?

24 the property though? 24 A. Uh- huh.

25 MR. BALDWIN: Correct. 25 Q. And there was also testimony about the
200 202

1 Q. BY MR. BALDWIN: Did you guys ever 1 funds that was paid for that vacant lot?
2 speak about the property in Eagle? 2 A. Yes.

3 A. She just told me I sell everything. I 3 Q. What was your understanding of those
4 said don' t sell it. Don' t do that. And she said 4 funds?

5 no, I' ll do it. She didn' t listen. 5 A. For the lot?

6 Q. Okay. Why don' t we go into -- open up 6 Q. Uh- huh.

7 and go to Exhibit No. 2. And if you go to page -- 7 A. Yeah.

8 on the bottom PE 0028, there is household for 8 and then we got a loan. So -- and we got a loan

9 goods and furnishings; do you see that? 9 for the house and then for the lot. So when I was
10 A. Yes. 10 in prison she was speaking she paid off all the
11 Q. Do you see the list of property that is 11 loans.

12 listed there? 12 Q. Okay. And what do you think that would

13 A. Uh- huh. Yes. 13 be a fair and equitable division of all of your
14 Q. Is there anything on that list -- is 14 property?
15 there anything that is not on that list that you 15 A. I think 50/ 50.

16 think you should receive? 16 Q. 50/ 50 of what?

17 A. I don' t know. 17 A. Of both homes -- house and lot.

18 Q. Did you guys receive some Persian rugs? 18 Q. Do you think you are entitled to

19 A. No, I didn' t. I just got two box of 19 anything else?

20 clothes, that is all I got since I come back. 20 A. The common account that we had. She

21 Q. I understand that. But I think Naghmeh 21 told me when I was in prison, she told me I made

22 has said that there is some large paintings that 22 gifts and speaking engagement.
23 she is willing to give back to you that she has in 23 So -- but I don' t know what she did with that

24 her possession? 24 money. Before we got conflict on the phone she

25 A. Okay. 125 told me that I have $ in a common account.
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 203 205
1 The 1 Last night again I tried to go to

2 that I receive. So 2 church, maybe I can communicate with someone. But

3 until that night I had land, home, stock and 3 people see me like a very addicted, abuser person.
4 house. Everything. 4 So the situation in this city is so poison. Last
5 But a week after that when we got 5 year was very hard for me to live here. But for
6 conflict I told her Naghmeh, I said if you want to 6 the sake of kids, yes, I will stay.
7 do these things I am going to get divorce. And 7 Q. If the Court were to follow
8 she said you cannot get divorce because you are a 8 would you stay here?
9 pastor. If you divorce me you are going to lose 9 A. No. Because that
10 everything. I said Naghmeh, you know I don' t care 10

12 But I don' t follow that presence of Lord that you 12 Q. So if the Court were to
13 say you received and I should follow you. I am 13 --
14 not that guy. And she said okay, go ahead and 14 A.
15 divorce me. 15 out. He write
16 And a week after that she just start 16 in the home,
17 and send me a text message I gave my stock to my 17 life.

18 dad. And I sold the land. And she emptied the 18 Q. And so if the Court follows that

19 account. And I just tried to send a letter from 19

20 prison to the judge, to the Court and come to you 20 A. Probably -- it depends to my financial
21 guys, but the prison didn' t let me to send it. 21 situation. If I can get my half of the money that
22 And at that time I wrote a letter to get divorced 22 we had, I am going to stay here or go get some
23 at that time. So since in prison I got my 23 place here in California.
24 decision to get divorced. 24 Q. When you say half of your money that
25 And when I came here Franklin Graham 25 you have, what are you referring to?
204 206

1 said just let me to try something. I said it 1 A. As she said to me, she

2 doesn' t work Franklin. So he hardly tried to 2 as she told me when I was in prison. And you know

3 bring some peace. And at the end Franklin called 3 as she told me in prison, we have
4 me and said Naghmeh is a dangerous person and you 4

5 need to get divorce of her. That doesn' t work. 5 everything. So half of it is going to be
6 Q. Okay. 6 something, $ If I get that

7 A. So I applied for divorce. 7 money I will stay here or I go buy a place in

8 Q. So your testimony was is that we should 8 California. If not I need to start from zero, go

9 divide everything up equal? 9 to Virginia. Franklin is helping me to find a job

10 A. Yes, sir. 10 there.

11 Q. But you believe there may have been 11 Q. So if the Court follows basically what
12 money out there that Naghmeh basically liquidated 12 is Exhibit 2, the division as Naghmeh provided,

13 your assets before you were released from prison? 13 you would leave; is that correct?

14 A. Repeat your question. 14 A. Yes.

15 Q. You have already answered my question. 15 Q. And you would go to Virginia; is that

16 A. Okay. 16 what you said?

17 Q. So in regards of remaining in Boise, do 17 A. Yes.

18 you believe that there is a chance for you to stay 18 Q. And you have --

19 in Boise and continuing your profession? 19 A. Stay with my family.

20 A. I will do everything I can do for my 20 Q. And you have work there?

21 kids. If I can have my kids I am going to stay. 21 A. Yeah.

22 But the problem is as she said, I killed you. I 22 Q. And if the Court were to follow

23 killed Saeed Ministries. She killed my ministry, 23 what type of visitation do you

24 my job. And the whole city is so poison against 24 think would be appropriate?

25 me. 125 A. If I go to Virginia?

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1 Q. Uh- huh. 1 MR. BALDWIN: Judge, I don' t think I have

2 A. It depends to my financial situation. 2 any further questions for Mr. Abedini at this
3 You know, if I can afford it, I will come every 3 point.

4 week to see them. If not, every other week. It 4 THE COURT: Why don' t we take about a
5 completely depends on my financial situation. If 5 ten- minute recess and we can start cross then.

6 not, at least once a month. 6 See you in a few minutes.

7 Q. You would like to see them at a minimum 7 Recess.)

8 once a month? 8 THE COURT: Ms. Stern, when you are ready
9 A. Yep. 9 you can begin cross.

10 Q. If your financial situation granted you 10

11 would like to have more time with them? 11 CROSS- EXAMINATION

12 A. Yes. 12 BY MS. STERN:

13 Q. And it would be -- would it be your 13 Q. Saeed, now, you testified earlier today
14 desire to eventually come closer to live by the 14 that you had been in Alaska for a couple of weeks.
15 children so you can be in their life? 15 Wasn' t it actually a couple of months?
16 A. Yes. 16 A. I don' t think so.

17 Q. But your belief is that you couldn' t 17 Q. When did you go to Alaska?

18 stay in Boise and make it? 18 A. I am very bad in memorizing dates and
19 A. No. The situation is so poison. And 19 numbers. I don' t know.

20 especially working here, the church it is corrupt 20 Q. Does mid June sound right?

21 here in Boise. There is so much corruption I 21 A. I don' t know. It was just like maybe a

22 don' t believe the leadership is happening right 22 month or less than a month.

23 now. So it is really hard for me. I should deny 23 Q. And you only will stay here if you can
24 myself every day staying here. But for the sake 24 get a 50/ 50 division of --

25 of kids I will do it. 25 A. I said yes.

208 210

1 Q. Did you own a couple of domain names, 1 Q. Now, wasn' t there a time early this
2 Saeed Ministries? 2 fall that

3 A. Yes. Saeedministries and ChurchofIran. 3 you with

4 There are two sites that I own it, but I don' t 4 A. Yes.

5 have it. Naghmeh cousin has it. They didn' t give 5 Q. And wasn' t that shortly after a
6 it to me. And so everything that was -- it was 6 had been entered?

7 Saeedministries on Facebook with 80, 000 or 7 A. I don' t know. I don' t remember. But I
8 something followers. Or prayforpastorSaeed, which 8 asked Jacob and he told me
9 Naghmeh has the password. She never gave it to 9 that we find

10 me. But the first lawyer told her that she needs 10 Q.Q. AndAnd Mr.Mr. Abedini,Abedini, didn'didn' tt youyou havehave aa
11 to give all the letters and communication that I 11 translator in court with you in 2007?

12 have, but I heard that she threw all of them to 12 A. I don' t think so.

13 the trash. Garage. 13 Q. Now, Mr. Abedini, you testified earlier

14 Q. It would be your desire that anything 14 that you think that Naghmeh raised about $ 700, 000
15 that she may have in regards to 15 while you were in prison; is that correct?

16 Saeedministries. com. ChurchofIran. com or Facebook 16 A. That' s what she told me when I was in
17 regarding your ministry that you retain possession 17 prison.

18 of that? 18 Q. Okay. But are you aware that while you

19 A. Yes. 19 were in prison she was able to pay off your

20 Q. And to the extent that she may have any 20 mortgage?

21 letters or anything -- 21 A. Yes, she told me she did it.

22 A. She said she put it in the garage. But 22 Q. And you were aware that while you were
23 she knows that my first lawyer sent her e- mail 23 in prison she was able to pay off the credit debt
24 that said Saeed wants that. But she tries to 24 the two of you had?

25 destroy everything. 125 A. We didn' t have any credit debt. We had

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 211 213
1 just loan for the house and lot. We didn' t have 1 Q. Okay. Now, what I would like you to do
2 any credit card. 2 is go back to, it is PE 0128.
3 Q. And were you aware that she had travel 3 A. 128?

4 expenses to advocate for you? 4 Q. And for the statement date, is that the
5 A. Yes, she told me. And I know that all 5 statement dated July 29th, 2016?
6 the travel has been paid off the ACU and the 6 A. Okay.
7 people who invited her. 7 Q. Is it a fair statement that that bank
8 Q. And that she was sending money to your 8 account had $ 269. 85?
9 family as well as supporting your children? 9 A. Yes.

10 A. My children? 10 Q. Okay. Now, going back to the first

11 Q. Yes. 11 page of this exhibit, PE 0111 and is that the
12 A. To my family? 12 statement for December 30th, 2016?

13 Q. She was sending money to your family? 13 THE COURT: Can you answer out loud, sir?
14 A. Uh- huh. 14 THE WITNESS: Yes.

15 Q. And that she was supporting 15 Q. BY MS STERN: And at that point this

16 as well? 16 account has 4, 215. 25; is that accurate?

17 A. Yes, for sure. But the money that has 17 A. Yes.

18 been sent to my family was from the church account 18 Q. Okay. Mr. Abedini, you were the only
19 under the ministry because my whole family were 19 one with control of this account, aren' t you?

20 the first people to help me start the churches in 20 A. At this time, yes.

21 Iran before we get married to Naghmeh. So they 21 Q. Okay. And Saeed Ministries Inc doesn' t
22 always helping me and the reason they got stuck -- 22 have -- this is Saeed Ministries Inc as well; is

23 You know my brother and sister they 23 it not?

24 never want to leave Iran they have a very 24 A. I don' t know what you mean.
25 successful life in Iran. But when I got arrested 25 Q. This belongs to Saeed Ministries?
212 214

1 they took them to interrogation so they were being 1 A. Yes.

2 forced with intelligent police of Iran to leave 2 Q. And Saeed Ministries is you?
3 Iran. So that money goes -- 3 A. Yes.

4 THE COURT: I am going to interrupt you 4 Q. But you are the one in control of this

5 because the question was in regards to money 5 account?

6 supporting the family. 6 A. At this time, yes.

7 MS. STERN: Okay. 7 Q. I would like to move you onto

8 THE COURT: So let' s go ahead and pose a new 8 Exhibit 9, please. Are you there?

9 question. 9 A. Yes.

10 MS. STERN: Thank you. 10 Q. Looking at that first page, does this
11 Q. BY MS. STERN: Saeed, at this point 11 appear to be your personal bank account at Zions
12 you' ve got -- if I can direct your attention to 12 Bank?

13 Exhibit 10 in the folder in front of you. Are you 13 A. Yes.

14 there? 14 Q. And is it a fair statement that as of

15 A. Yes. 15 January 6th, 2017, you had $ 11, 780. 12 in your

16 Q. Okay. And is that a Saeed Ministries 16 simple checking account?

17 Inc bank account that your name is on? 17 A. Yes.

18 A. On the first page? 18 Q. Mr. Abedini, isn' t it true that since

19 Q. Yes. 19 you got out of prison and have been here for the

20 A. Yes, Saeed Ministries Inc. 20 past year you have not provided Naghmeh any funds
21 Q. And if you want to take a minute to 21

22 look. Do those appear to be the bank account 22 you?

23 statements for Saeed Ministries Incorporated? Is 23 A. She didn' t ask for it.

24 it accurate to say that that is what those are? 24 Q. That is not what I asked. You haven' t

1125 A. Yes. 125 provided her with any?

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1 A. No. 1 Q. BY MS. STERN: You' ve been living at

2 Q. And in fact, if we go back to refer you 2 the now you

3 to page 0099. 3 testified for about a year; is that correct?

4 THE COURT: Of Exhibit 9, okay. 4 A. Yes.

5 MS. STERN: We are still on Exhibit 9, it is 5 Q. Who has been paying that rent?
6 page 0099. 6 A. My sister.
7 Q. BY MS. STERN: About half way down the 7 Q. So you have not paid that?

8 page transaction dated 9- 29. It appears that you 8 A. No.

9 spent $ 4, 000, did you not, on It' s Just Lunch? 9 Q. And again, how much is in that account

10 A. Yes. 10 now?

11 Q. Can you tell me what It' s Just Lunch 11 A. I don' t know. Maybe $ 4, 000. 5, 000.

12 is? 12 Q. And you still haven' t provided any

13 A. Should I tell that? 13 funds to Naghmeh?

14 MR. BALDWIN: You can answer the question. 14 A. What is the question again?

15 THE COURT: You need to answer the 15 Q. You still haven' t provided her any
16 questions. 16 funds?

17, THE WITNESS: It is a dating site. 17 A. No.

18 Q. BY MS. STERN: So you paid $ 4, 000 to 18 Q. Mr. Abedini, you regularly communicate
19 join a dating site? 19 with your

20 A. Yes. 20

21 Q. And let me direct your attention to, 21 A. I talk to her.

22 still Exhibit 9, page 0101. And is that a copy of 22 Q. But you tell her when you are going to
23 a check you wrote to your sister? 23

24 A. Yes. 24 A. Yes, I do.

25 Q. And the date on that check is 25 Q. And in fact, you have had her

216 218

1 8- 31- 2016? 1

4 that $ 3, 500? 4 A. I

5 A. Yes. She was helping me -- she was the 5 doesn' t answer my call or text. And any time I
6 only person that helped me after I came back from 6 told something she put me in trouble, problems, by
7 prison. Naghmeh shut down all the accounts, 7 calling police. And so because of that -- through

8 everything, so I was completely homeless. 8 my lawyer, I told her --

9 THE COURT: I think you have answered the 9 like, they
10, question, sir. Thank you. 10 So maybe going to be five- minute late. So we
11 THE WITNESS: So she was helping me and I 11 already talk about it, but
12 sent that check back to her -- 12 about it. But when it became 7: 00
13 Q. BY MS. STERN: I just need you to 13

14 answer the questions I ask you. 14 at 7: 00 and it's kinds of like --

15 A. You said why you sent her the check, I 15 THE COURT: I think the question is about

16 am explaining why. 16 whether you are and

17 THE COURT: I think there was a 17 not so much what the content was, unless there was

18 miscommunication there. I think he thought you 18 a question about content?

19 were asking the question. 19 MS. STERN: There wasn' t a question about

20 MS. STERN: Okay. 20 content, Your Honor.

21 THE COURT: I think she was just clarifying 21 THE COURT: Thank you, Ms. Stern. You can

22 it. I think there was a genuine misunderstanding 22 ask another question.

23 there. But there is not a question pending right 23 Q. BY MS. STERN: Now,

24 now. So Ms. Stern, you can go ahead and move on. 24

25 MS. STERN: Thank you, Your Honor. 125 A. Yes.

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 219 221

1 Q. And in March of -- and you went to 1 THE COURT: Okay.

2 California right after that for about six months, 2

3 correct? 3 REDIRECT EXAMINATION

4 A. No. 4 BY MR. BALDWIN:

5 Q. When did you say you went to 5 Q. Mr. Abedini, if you can turn to Exhibit
6 California? 6 No. 10. That is the Saeed Ministries Inc.
7 A. I was in California maybe more than 7 account; is that correct?

8 one -and -a -half month. 8 A. Yes.

9. 9 Q. Is there anybody else associated with

10 Q. And isn' t it true that you actually had 10 the Saeed Ministry?
11 a trip to Iran in 2009, as well? 11 A. We have boards, which my sister and
12 A. Yes. Naghmeh told me to do that. 12 Naghmeh was in it, but we fired her. So just my
13 Q. And the entire time that you were at 13 sister.

14 home in Boise with Naghmeh' s 14 Q. Who is in it now?

15 15 A. Just my sisters.
16 A. Yes. 16 Q. So it is just not you, you have access
17 Q. And you had the nanny coming three 17 to this money but there is also other people
18 times a week, correct? 18 involved with Saeed Ministries?

19 A. I don' t think three times. Yeah. She 19 A. Yes.

20 sometimes came. And sometimes it was two or three 20 Q. Okay. And if you would turn to page PE
21 hours or something. She wasn' t really good help. 21 0090, which is part of Exhibit 90 -- I' m sorry
22 But Naghmeh did it because Naghmeh loves her 22 Exhibit 9?

23 pastor, she wants to help them financially. So 23 A. The page again?

24 that was the reason she came, but she wasn' t help. 24 THE COURT: The bates number again,
25 Q. I know this is -- I really just need 25 Mr. Baldwin?

220 222
1 you to answer the questions that I ask. I know it 1 MR. BALDWIN: PE 0090.

2 can be difficult. 2 Q. BY MR. BALDWIN: Are you on that page?

3 A. Okay. I will try my best. 3 A. Yes.

4 THE COURT: Thank you. 4 Q. At the top where it says two

5 Q. BY MS. STERN: Mr. Abedini, you have 5 deposit/ credits, can you see that? Are you on

6 now pled guilty to a no -contact order violation, 6 page PE 0090?

7 have you not? 7 A. 0090, right.

8 A. What is that again? 8 Q. Do you see where it says two

9 Q. You have pled guilty to a no -contact 9 deposit/ credits?

10 order violation, have you not? 10 A. No.

11 A. With the kids? What do you mean? I 11 Q. One that is dated 11/ 09?

12 don' t know what that word means. 12 A. Okay. Yeah, I got it.
13 Q. You have pled guilty to another 13 Q. For $ 4, 000?

14 criminal action, have you not? 14 A. Yeah.

15 A. You mean the one like last month? 15 Q. Is that for It's Just Lunch?

16 Q. Correct. 16 A. No, I don' t think so.

17 A. Yes. 17 Q. Is that what it says there?

18 Q. And you actually have a sentencing in 18 A. Is it Saeed Ministries?

19 that coming up this coming up Monday, correct? 19 Q. No. It should be page PE 0090. Are

20 A. Yes. 20 you on that page?

21 MS. STERN: Your Honor, I don' t have any 21 A. Right.

22 further questions. 22 Q. On top it says Zions Bank simple

23 THE COURT: Mr. Baldwin, anything else? 23 checking account?
24 MR. BALDWIN: Yes. Just a couple of 24 A. Yes.

25 follow- ups to hers. 25 Q. And then you should go down a little

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 223 225

1 NAGHMEH PANAHI,
1 bit. There should be two deposits right at the
2 2 Recalled as a witness at the instance of the
top of the page?
3 A. Uh- huh. 3 petitioner, having been previously duly sworn, was
4 Q. You see that? 4 examined and further testified as follows:

5 A. Yes. 5

6 Q. One is for $421 and one is for $4, 000; 6 THE COURT: Ms. Stern, when you are ready.

7 do you see that? 7

8 A. Got it. 8 DIRECT EXAMINATION ( Continued)

9 Q. Is that $ 4, 000 credit from It' s Just 9 BY MS. STERN:

10 Lunch? 02: 13 10 Q. Naghmeh, you were in the courtroom for

11 A. I don' t know. 02: 13 11 the entire time that Saeed testified, correct?

12 Q. Is that what it says? 02: 13 12 A. Correct.

13 A. I don' t know. 02: 13 13 Q. I am going to ask you some questions

14 Q. Can you read over there and -- 02: 13 14 that specifically relate to that?
15 A. I am trying to find it. 02: 13 15 A. Okay.
16 Q. Did you, in fact, cancel your It' s Just 02: 13 16 Q. I just need you to answer the questions

17 Lunch, that dating service? 02: 13 17 okay?

18 A. Yes. 02: 1318 A. Okay.

19 Q. And would that $4, 000 be a credit back 02: 13 19 Q. Saeed testified that

20 to your account from cancelling that? 02: 13 20 do you remember that

21 A. Yes. 02: 13 21 testimony?

22 MR. BALDWIN: I have no further questions on 02: 13 22 A. Yes.

23 redirect. 02: 13 23 Q. Have you ever told him that -- told the

24 THE COURT: Anything else, Ms. Stern? 02: 13 24

25 MS. STERN: No, Your Honor. 02: 13 25 A. No.

224 226

1 THE COURT: Okay. Sir, you can step down. 1 Q. Have you talked poorly about him in
2 Thank you. 2

3 Mr. Baldwin, do you have any other 3 A. No.

4 witnesses today? 4 Q. When you talk about Saeed to Saeed and

5 MR. BALDWIN: I do not, Your Honor. 5 your children, how do you talk -- what do you talk

6 THE COURT: So you would rest? 6 about? How do you address that?

7 MR. BALDWIN: Yes. 7 A. The extent of what I have told them

8 THE COURT: Ms. Stern, any rebuttal? 8 because they have asked
9 MS. STERN: Yes, Your Honor. 9

12 Panahi, please. 12 I have

13 THE COURT: Okay. Ms. Panahi, I will remind 13 I actually have noticed that when I
14 you you are still under oath. Let' s go ahead and 14 talk about how
15 have you have a seat back up in that green chair. 15

16 16 really take pride in that. So I' ve tried to

17 17 reinstate in them their part that is Saeed and

18 18 their love and respect for him. But they have

19 19 asked about why
20 20

21 21 Q. Have you ever

22 22 A. No. That' s been the extent of me

23 23 saying. There has been things

24 24 and I haven' t
25 25 Q. Do you believe that it is appropriate
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 227 229
1 that the 1 A. He does.
2 A. Yes. That' s how -- that' s a healthy 2 Q. And what is that?

3 3 A. In Taekwondo he has a really high belt.

4 much I speak about Saeed or Saeed 4 Like a black belt or some sort. Or brown belt,
5 about me, 5 something.
6

8 Saeed Ministries?

9 with 9 A. No.

10 Q. Now, at any point did anyone from your 10 Q. Were you in the courtroom when he
11 church direct you to speak poorly about Saeed? 11 testified to you telling him that you had had some
12 A. From my church? 12 sort of a vision that you were going to leave him
13 Q. From Calvary Chappal Boise? 13 and destroy him?
14 A. No. I think even Saeed said in his 14 A. No.

15 testimony he was brought up. And even when he 15 Q. Did that ever happen?
16 returned from Iran, Bob Caldwell had him up on 16 A. No.

17 stage and people clapped for him and gave a 17 Q. Do you have any problem with him having
18 standing ovation for him. And he was able to 18 anything that you might have from Saeed Ministries
19 speak on stage about how thankful he was for the 19 or Churchoflran. com?

20 support. The church in Boise was his biggest 20 A. No.

21 support. 21 Q. Did he ever tell you not to sell the

22 Q. To the best of your knowledge when he 22 property?
23 was in Court for the criminal action in 2007 was 23 A. No.

24 there a translator provided? 24 Q. And as to the stock, did you have any
25 A. There was. I believe in the report it 25 stock from the company that you received after you
228 230
11 actually also says. There was a woman, Iranian 11 got married?

2 translator, that explained everything to Saeed. 2 A. No.

3 Q. And he was represented by counsel? 3 Q. So it was all from before when you were
4 A. I don' t remember that. I got a lawyer. 4 teenager?

5 He might have been both of our lawyers. There was 5 A. Correct.

6 a lawyer. 6 Q. After you cut off con -- after the last

7 Q. There was a lawyer for the criminal 7 conversation you had with him in prison, did you
8 action? 8 have occasion to send that e- mail he testified

9 A. Correct. 9 about?

10 Q. Did you punch him in his face in Dubai? 10 A. No. I stopped all communication when

11 A. No. 11 I -- end of October. He did send me a few texts

12 Q. Did you attack him in Dubai? 12 saying his family wanted $ for medical, but
13 A. No. 13 I had stopped talking to him and communicating
14 Q. Have you ever punched him? 14 with him since the end of October.
15 A. No. My extent as I described earlier 15 Q. Do you recall who wrote the power of

16 has been shaking his shoulder and asking him to 16 attorney that you had?
17 speak with me. I think Saeed said in his 17 A. Jay Sekulow. Their lawyer. ACU
18 testimony he has -- he was trained by radical 18 wrote --

19 Muslim group so he is stronger and more trained 19 Q. Let' s make some clarification. What is

20 than I. 20 ACU, both of you have mentioned that a couple of

21 THE COURT: This is becoming a narrative. 21 times?

22 Let' s just try to stick to the question and 22 A. American Center for Law and Justice.

23 answer, please. 23 And Jay Sekulow is the president of that

24 Q. BY MS. STERN: Do you know whether or 24 organization.

25 not Saeed has any training in marshal arts? 125 THE COURT: Could you spell his last name,
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 231 233

1 please. 1 property -- my mom' s Lexus car window was smashed

2 THE WITNESS: S - E - K - U - L -O -W. 2 and -- do you want me to explain that situation?

3 THE COURT: Thank you. 3 Q. If I want you to I will ask you the

4 Q. BY MS. STERN: And was Mr. Sekulow 4 question.

5 5 A. There were two incidents that were

working with Saeed during this time?
6 A. Well, I was his client. The contract 6 called -- the police were called, but there were

7 was between me and Jay Sekulow in an attempt to 7 many incidences that they were not.
8 get Saeed out. But I was his direct client. 8 Q. This incident having to do with the
9 Q. Okay. Now Naghmeh, Saeed testified in 9 Lexus window being broken, were the police called
10 his direct exam to an incident where he -- when he 10 then too?

11 broke your father' s nose. Do you recall that 11 A. Yes.

12 testimony? 12 Q. What was that?

13 A. Yes. 13 A. What happened?

14 Q. Do you believe that his version of what 14 Q. Yes.

15 happened is accurate? 15 A. Saeed was acting angry and I told my

16. A. No. 16

V Q. Could you please explain what you 17 I think it was like

18 believe happened the day he broke your father's 18 2009 maybe. It was around 2009. Yeah. It was

19 nose? 19 2009, summer of 2009.

20 A. Yes. My father picked up his mom, my 20 And I told my parents

21 grandma, from her house as he does two times a 21 let' s go. And so we got in my parent' s car. I
22 week and brings her to the house. Their house. 22 said let' s or something and
23 And my grandma was saying -- they were talking, 23 had ice cream and came back and

24 standing, talking and she was saying to him that 24 thought the house was vandalized.

25 she doesn' t get to see him enough and he doesn' t 25 Because as soon as we got into the

232 234

11 spend as much time with her. And he was 11 garage there was holes in the garage wall. There

2 frustrated saying I' m busy, I have businesses. 2 was -- the Lexus car window was shattered. There

3 And I got in the middle and I said let' s just not 3 was holes inside the house in the living room. TV
4 argue. And he said this is between me and my mom. 4 was slashed, broken. Like LCD TV. My parent' s
5 And the next thing I knew my dad was being beat up 5 bedroom was trashed and their lamps were broken.

6 very close to the encounter I had in Dubai. Kicks 6 We just thought someone rampaged through the house

7 and punches to the head and -- kicks and punches. 7 looking for money or something.
8 Q. And when you say your dad was being 8 And so we that
9/ beaten up, who was beating him up? 9 someone had come into our house and Saeed was

10 A. Saeed. 10 sitting on the couch. And he was just very calm

11 Q. Had your dad been threatening you? 11 and he said I just want you to know I am not

12 A. No. He said this is between me and my 12 angry. I want you to know you can' t do that.
13 mom and the next thing we knew he was attacking 13 Next time ask my permission. And he was very calm.
14 him. Saeed was. 14 He said I am not angry, I didn' t do this out of
15 Q. Was he threatening your grandmother? 15 anger. Just next time you ask my permission
16 A. No, they were just arguing about the 16 before you leave.

17 time he should be spending with her. 17 MS. STERN: I have no further questions,

18 Q. And when was that? 18 Your Honor.

19 A. Summer of 2010, I believe. 19 THE COURT: Mr. Baldwin, any cross?

20 Q. And during that period of time were 20

21 there other occasions that Saeed had been violent 21

22 at your parent' s home? 22

23 A. He was. The violence continued to my 23

24 family. But the onces that were recorded were the 24

25 nose incident and him breaking my -- breaking 125

nn ineien. no. on. onn Done 111 fn') Zd of' 2AA SR of 61
 235 237
1 CROSS- EXAMINATION 1

2 BY MR. BALDWIN: 2 THE WITNESS: Yes.

3 Q. So those incidents you just described, 3 THE COURT: Or

4 were there ever any criminal charges brought 4

6 A. No. We asked the police not to. 6 THE WITNESS: No.

7 Q. You testified earlier that you told 7 THE COURT: Okay. But you think -- okay.
8 your 8 Thank you.

9 you are 9 MS. STERN: I can ask a follow- up question

10 A. Correct. 10 too for that?
11 Q. Did you 11 THE COURT: If you could that would be
12 12 great.

13 A. I did not or else I would not have let 13 MS. STERN: Have you
14 them spend so much time with him when he was first 14 whether or --

15 released. I actually told the judge initially 15 THE WITNESS: Yes.

16 that when I got my protection order I said I don' t 16 MS. STERN: -- in getting that changed?
17 think he is 17 THE WITNESS: She would.
18 wants. 18 THE COURT: Thank you. You can step down.
19 Q. And this protection order ultimately 19 Unless Mr. Baldwin has any questions?
20 got dismissed, correct? 20 MR. BALDWIN: I don' t.

21 A. The initial one because we filed for 21 THE COURT: Anything further, Ms. Stern?
22 legal separation, correct. 22 MS. STERN: Your Honor, I am trying to make
23 MR. BALDWIN: No further questions. 23 a decision.

24 THE COURT: Anything further? 24 THE COURT: Take a minute. Go ahead. i

25 MS. STERN: No, Your Honor. 25 MS. STERN: I am going to recall Homy Panahi
236 238
1 THE COURT: Okay. Ma' am, you can step down. 1 briefly.
2 Actually, I have one question. I just wanted to 2 THE COURT: Okay.
3 confirm when I looked at your property and debt 3

4 schedule and the testimony that I have heard, you 4 HOMY PANAHI,

5 are asking that I allow 5 Recalled as a witness at the instance of the

6 Given that your 6 petitioner, having been previously duly sworn, was
7 is it your understanding 7 examined and further testified as follows:

8 that you can 8

9. THE WITNESS: Correct. 9 THE COURT: Mr. Panahi, come forward. I

10 THE COURT: So that is your understanding? 10 will remind you you are still under oath from

11 You think you have the ability to go down and 11 being sworn in earlier. If you will kindly have a
12 12 seat up there. Ms. Stern has a couple of more
13 THE WITNESS: I can do 13 questions for you. So you can go ahead and have a
14 14 seat. You are still under oath. Thank you.

15 THE COURT: I am not ordering you to do 15 THE WITNESS: I brought the wrong glasses.
16 that. I am just asking you what your 16 THE COURT: Have a seat, sir. If you need

17 understanding is. I just want to make sure I have 17 any assistance we will see if we can help you.
18 the If you are not 18 Go ahead.

19 the -- 19

20 THE WITNESS: I can 20 DIRECT EXAMINATION ( Continued)

21 THE COURT: What authority do you think you 21 BY MS. STERN:

22 have to do that? You think if you went down to 22 Q. Mr. Panahi, do you recall an instance

23 23 when you had your nose broken?

24 THE WITNESS: I can with 24 A. Yes.

25 THE COURT: But would your 125 Q. Was this in 2010?

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 239 241

1 A. I believe so. About five or six years 1 A. That was it.

2 ago, yeah. 2 MR. BALDWIN: No further questions.

3 Q. Who broke your nose? 3 THE COURT: Ms. Stern, anything else?
4 A. Mr. Abedini. Saeed. 4 MS. STERN: I do not have anything else.
5 Q. Can you please tell the Court what 5 And Mr. Panahi can be excused.

6 happened that led to that -- him breaking your 6 THE COURT: Thank you, sir. You can either

7 nose? 7 go about your day or stay in the courtroom.

8 A. My mom was 91 years old, I usually take 8 THE WITNESS: Okay. Thank you.
9 my mom home to spend some time with her. And 9 THE COURT: Thank you so much.

10 during the driving she was complaining about my 10 Anything further, Ms. Stern?
11 daughter. And when I got home I said mom, I am 11 MS. STERN: I do not, Your Honor.

12 tired. Can you be quiet. And Naghmeh said why 12 THE COURT: Okay. All right.
13 you talk to your mom like that? I said this is 13 I have a couple of brief questions for

14 between me and mom. And then Saeed said, why you 14 Ms. Panahi and Mr. Abedini while they are still
15 talk to my wife like that? And beat me up. 15 under oath. Your attorneys made some

16 Q. And did that cause you to need to go to 16 representations in regards to some stipulations

17 the hospital? 17 about your retirement account, some irreconcilable

18 A. Yes. Yes. I have to. Many places was 18 differences, computed income regarding your
19 broken. I went through two surgeries and still 19 earnings, I think those were the main

20 have a problem. 20 stipulations. Do you both agree that those are

21 Q. Did you decide not to press charges for 21 the stipulations of the parties?

22 that? 22 MS. PANAHI: Correct.

23 A. My wife ask me not to do. 23 THE COURT: Mr. Abedini? Can you answer out

24 MS. STERN: I have no further questions. 24 loud. Are you in agreement, sir, that there are

25 THE COURT: Mr. Baldwin, any cross? 25 irreconcilable differences?

240 242

1 MR. BALDWIN: Sure. 1 MR. ABEDINI: Yes.

2 2 THE COURT: That you should be calculated at

3 CROSS- EXAMINATION 3

5 Q. So on this incident was there any 5 MR. ABEDINI: Yes.

6 threatening to Naghmeh by you? 6 THE COURT: And you agree that the

7 A. Never. That' s not true. 7 retirement account that was discussed that you

8 Q. She got in the middle of you and your 8 have an agreement that it should be divided

9 mother? 9 equally?

16 A. She just said don' t talk to your mom 10 MR. ABEDINI: Yes.

11 like that, that' s it. 11 THE COURT: Okay. All right.

12 Q. Did he get in between you and your mom? 12 MS. STERN: Your Honor?

13 A. No. 13 THE COURT: Yes, ma' am.

14 Q. Where did she say -- 14 MS. STERN: I believe that Ms. Panahi wants

15 A. She said don' t talk to my mom -- to 15 me to do the first draft of the qualified domestic
16 your mother like that. 16 relations orders. And so I will volunteer to do

17 Q. And where was Mr. Abedini when that was 17 that. On the retirement account I will coordinate

18 said? 18 with Mr. Baldwin to get that taken care of.

19 A. Mr. Abedini was -- Mr. Abedini was 19 MR. BALDWIN: I wont argue with that.

20 about two or three feet away from her, the other 20 THE COURT: Okay. Do the parties have a
21 side. 21 preference in regards to closing remarks and
22 Q. Okay. And right after -- did you 22 whether they are oral, written, today or another
23 respond to Naghmeh? 23 day? Ms. Stern?
24 A. No. I said this is between me and mom. 24 MS. STERN: I have no preference. I can' t

25 Q. And that was it? 125 guarantee how much more my voice is going to hold
A' f .. F 7AL rn of Zi Ch CO*
vim, w, cvii vc.. y.. .,.., -.... ...
 243 245
1 out. But that might actually make me brief. It' s 1 order issued January 26th the parties were
2 up to you guys. 2 originally, and in all cases, prohibited from
3 MR. BALDWIN: I would just assume be done. 3

4 If Fran doesn' t feel well, I don' t have a problem

5 doing it the other way too. But I would prefer to 5 That is still
6 be done sooner rather than later. 6 the order of the Court and I expect the parties to
7 MS. STERN: I will buck it up. 7 abide by that from today' s date forward. I mean I
8 THE COURT: Well, it' s whether there is -- I 8 expected you to abide by that from January 26th
9 had contemplated a possibility of written 9 forward, but I am admonishing the parties to
10 closings, but I don' t now how counsel feels about 10 remember that joint temporary restraining is in
11 that. There are a couple of legal issues in 11 place.

12 regards to property that may have a couple of knew 12 I would also like to have an actual
13 answers you wanted to spell out for me, but I 13

14 don' t know if that is something you want to do

15 orally or in writing?
16 MR. BALDWIN: I have no objection to doing
17 written if that is what the Court wants. 17 for review by their clients. I do not want it
18 MS. STERN: If the Court wants it written I 18

19 will do a written one.

20 THE COURT: It can be short written or long
21 written depending on what you want me to consider.
22 There might be a couple of things I might be
23 asking you to tie up for me, Ms. Stern. 23 going to need to let me know
24 MS. STERN: As long as they are 24 of that.

25 simultaneous, I don' t care. 25

244 246
1 THE COURT: Any objection, Mr. Baldwin, to 1

2 simultaneous written closings? 2 You look like

3 MR. BALDWIN: No, that is fine. 3 you may have a question, Ms. Stern.
4 THE COURT: How much time do you need to 4 MS. STERN: No, Your Honor.

5 prepare them? Three weeks, March 1st? What do 5 THE COURT: And I am probably not being
6 you think? 6 terribly succinct. I just think it would be nice
7 MS. STERN: I can do it no later than 7 to have
8 March 1st. 8

9 MR. BALDWIN: Yeah. I can do that.

10 THE COURT: If that is too far out, I am
11 happy to shorten that up. If the parties don' t
12 want that much time. We can have them due on the
13 21st of February, which is two weeks from 13 Mr. Baldwin, can you please prepare the

14 tomorrow, unless that is too short? 14 order on that?

15 MR. BALDWIN: I think I can do it by then. 15 MR. BALDWIN: Yes.

16 MS. STERN: Your Honor, I think I can do it 16 THE COURT: Anything else we need to take up
17 by the 21st. 17 today?
18 THE COURT: Is that workable, Mr. Baldwin? 18 MS. STERN: I don' t think so, Your Honor.

19 MR. BALDWIN: That is work able. 19 THE COURT: Okay. Well, I will look forward
20 THE COURT: So let' s have written closings 20 to your closing arguments coming through the door
21 due to the Court by Tuesday, February the 21st. 21 on the 21st.

22 I also note that we have had some 22 Thank you very much for your time and
23 discussion today about 23 efficiency today.
24 24 We will be in recess.

25 would note in the joint temporary restraining 25 ( End of audio -recorded proceedings.)
Page Z43 t0 Z4b OT Z4b u t/ ua/ cvii vcco7. ci rri
61 Of 61 sheets
 247

STATE OF IDAHO )

County of Ada )

I, Vanessa M. Starr, Official Court

Reporter, County of Ada, State of Idaho, hereby certify:

That I correctly and accurately transcribed

the above transcript from the audio - recording of the

court trial, which took place on February 6, 2017; that

the foregoing pages, 3- 246, are a true and correct

record of that proceeding, to the extent that the

audio - recording from which it was transcribed was

audible and discernible.

Dated and certified this 3rd day of April

2017.

Vanessa M. Starr, Transcriber

200 West Front Street, Suite 2168

Boise, Idaho 83702
208) 287- 7584