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EXPERT

EXPERT GREGORY METNHARDT -. 01/10/2018


GREGORY MEINHARDT 07/10/2018

SUPERIOR COURT
SUPERIOR OF CALIFORNIA
COURT OF CALIFORNÏA
COUNTY OF
COUNTY ORANGE
OF ORANGE - CENTRAL JUSTICE CENTER
CENTRAL JUSTICE CENTER

---ooo---
- --000 - - -

FORD
FORD MOTOR CREDTT COMPANY,
MOTOR CREDIT COMPANY, ))
LLC,
LLC, ))
))
PLAINTIFF,
PLAINTIFF, ) )
) )
vs.
VS. )) NO.
NO.
30-20 1 5-0 0 82 325A-CL-
)) 30-2015-00823254-CL-
LUANN ALBERT-SHERIDAN
LENORE LUANN
LENORE ALBERT-SHERÏDAN )) cL-cJc
CL-CJC
AND DOES
AND DOES 11- THROUGH
THROUGH 10,
10 , ))
))
DEFENDANTS .
DEFENDANTS. ))
))
))
ALBERT,
LENORE ALBERT,
LENORE ))
))
cRos s -coMPLATNANT /
CROSS-COMPLAINANT, ))
))
VS.
VS. ))
))
FORD MOTOR CREDTT
FORD MOTOR COMPANY, LLC,
CREDIT COMPANYT LLC, ))
A BUSINESS
A ENTITY, FORM
BUSINESS ENTITY, FORM UNKNOWN;
UNKNOWN; ) )
FRIENDLY FORD, AA BUSINESS
FRTENDLY FORD, ENTÏTY/ )
BUSINESS ENTITY,)
FORM
FORM UNKNOWN; KRAVITZ'
UNKNOWN; KRAVITZ, ) )
scHNrrzER && JOHNSTON,
SCHNITZER JOHNSTON, CHTD;
CHTD; ) )
GARY SCHNITZER; MELANTE
GARY SCHNTTZER; MELANIE MORGAN;
MORGAN; ))
AMY ROSE; THE
AMY ROSE; THE DUNNING LAW FIRM,
DUNNING LAVV FIRM, ))
PAC; DONALD
PAC; DONALD T.T. DUNNING;
DUNNTNG; ))
JAMES MACLEOD; AND DOES
JAMES MACLEOD; AND DOES ].
1 THROUGH)
THROUGH )
100, INCLUSIVE,
100, rNcLUSrvE, ))
))
CROSS-DEFENDANTS.
CROSS_DEFENDANTS . ))
))

VIDEOTAPED OF EXPERT
DEPOSfTTON OF
VIDEOTAPED DEPOSITION EXPERT GREGORY MEINHARDT
GREGORY MEINHARDT

WEDNESDAY, 10, 2018


JANUARY 10,
VüEDNESDAY, JANUARY 20L8

NO. 118868
JOB NO.
JOB 118868
REPORTED BY:
REPORTED BY : BARBARA
BARBARAPROKOP,
PROKOP CSR NO . 14190
CSR NO. 1- 4 1- 9 0
'

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GREGORY MEINHARDT 07/70/2078

1
1 Q
O And if the
And if the court t.hat you
court determines that you can
can

2
2 tes ti fy as
testify as an expert witness
an expert for Ms.
witness for Albert at
Ms. Albert at trial
trial-
3
3 and you
and have to
you have drive down
to drive here and
down here and testify for her
testify for her
44 in court,
in court, do
do you anticipate charging
you anticipate charging her for that?
her for that?
02:21
02:2I 5q Or you do
would you
Or would do that pro bono?
that pro
66 A
A not charge
II would not her for
charge her for that.
that.
71 O
Q Letme
Okay. Let
Okay. meask your without
ask you, let me
wit.hout -- let
8oU just ask
just you, without
ask you, without even
even looking your report
at your
looking at report
99 first., have
first, you formulated
have you formul-ated opinions in this
opinions in this case
case
02:21 10
02:21 L0 regarding citizens?
sovereign citizens?
regardi-ng sovereign
11
11 A
A I've formulated
I've opinions regarding
formulated opinions tactics
regarding tactics
12
L2 and behaviors and
and behaviors and other actions that
other actions are consistent
that are consistent
13
13 with the
with the behavior of sovereign
behavior of sovereign citizens, âs II know
citizensr as know

I4
14 sovereign citizens, which
sovereígn citizens, is commonly
which is interpreted as
commonly interpreted as

02:22 15
02:22 L5 by the
such by
such law enforcement community.
the law Yes, II have.
community. Yes, have.
L6
16 O
Q And what
And did you
wh t- did review before
vou review befor opining
oÐlnancI in
l-n

r-l
17 this case?
this
18
1B AA e vt-e wecl the
IIT reviewed ô f E-mails,
q.êrt ês of
the series B-mail a
19
L9 documents, social media,
ancl social
documents, and a ncl through
media, and throrroh
02:22 20
02:22 20 NV rs at
conversations relayed to me by Ms.
M Albert of the

2I
21 t involved in this
actions of people t case.
S

22
22 Q
a Did you review
Did you review any depositions?
any depositions?
23
23 A Yes, II did.
Yes, did.
24
24 Q
U Whose?
Whose ?

02:22 25
02:22 25 A II think it was
think it Monica Jones
was Monica or --
Jones or

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GREGORY MEINHARDT 07/TO/2078

1
1 O
Q So understand that.
SoII understand But there's
that. But quite aa
there's quite
2
2 in this
few documents in
few case, and each
this case, each document
document may
3
3 something different.
suggest something
suggest So II want
different. So to know
want to know what
what.

44 you --

02:24 5ã A
A If you
If you want to show
want to it to
show it fllêr II can
to me, tell-
can tell
66 you whether T
you whether read it
I read it or not. II would
or not. would remember it.
remember it.
77 O r h
So everything you reviewed was something

8 af I \rên lo
given to vyou
lr hr¡ Ms. AI
by Mq lre T t- Is
Albert. lh¡l
T.s that fai r2
fair?

9 A That is
That is correct,
orrect-, yeah.
veah -

02:24 I0
02224 10 O Is
T h re anything you reviewed that
there ha

11
11 Ms. Albert did
Ms. Albert not give
d ct not oive you in order
vou in to formulate
order to formulate
12
L2 vour opinions
your ôn this
opinions on this case?
case?
13
13 A
A No.
No.

14
L4 O An you indicated that some off the
Okay. And

02:24
02t24 15 thinos you
things re vi ewed were
vou reviewed r^rere conversations that- she
conversations that she told
told
I6
16 vôu about.
you Is that
about. Is t a1-what
what- IT heard?
heard?
17
L7 AA InTo I I
Well, nn
no. 'l.h a ra were
There rrrê rã conversations
^/lñ17ôrq¡l t Þr r t we
I n q. that r^7ô

18
1B had about
had ac t i ons that
about actions that were
hrere involved i n the
involved in the case.
case.
I9
19 There conversations --
were conversations
There were manv, many
-- many, conversations
manv conversations
02:24 20
02t24 20 over the phone, man h rs how,
many E-mails. And that's h you

2L
21 know,
n NV r
lust -- the conversations rrn
start triggering

22
22 thinos that
things ha \/ê happened
i-hat have to you
hannenecl to vou or t e victims
or the r¡ì ctims in
in
23
23 vour cases,
Your cases, and vou easily
and you reco ize them.
easilv recognize them

24
24 They're not common
mm to publications orr the

02:25
02 25 25 academic
a w r1
world. I
They're Íìm nto
common to, you know, the

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GREGORY ME]NHARDT _ 01/10/2018
MEINHARDT - OT/LO/2OIB

1
1 victims
victims the people
and the neonle involved
involved in
in the
t e courts
r:oirrt.s who
who

2
2 h law enforcement officers.
are the T Li I had talked
Like
3
3 to a couple -- two days ago, I talked to two
4
4 Riverside sheriff's
Riverside sheriff's deputies because II lust
deputies because iust wanted
wanted
02:25
02:25 5
6 to run
to run something
somethi o off
off of them.
of them.
6
6 And
And it's just amazing
it.'s just it triggers
how it
amazing how triggers --
7
'7
based
based on your own experiences
on your quíckly --
experiences -- very quickly
8
B tactics by
tactics by so-cold
so-cofd sovereign citi zens or
soverer-gn citizens or Moors
Moors or
9Y free people
free that have
people that have some kind of
some kind of vernacular
vernacul-ar
02:25 I0
10 associated with freedom
as s ociated with of speech
freedom of or whatnot.
speech or whatnot.
11
11 0 So t me
o Mr. Meinhardt, let m ask you before
12
1"2 1 r understanding.
too -- because I don't have a clear
13
13 What do you view
r,¡/ as your Qualifications t allow you
]' n to

14
1,4 t-o opine
to abolrt sovereign
ooine about sovei:eion citizens?
iiliz.ens?

02:26
02:26 15
15 A Living : ncl breathino
Livin cf and breathing it an ci actually
it- and ar:tuallv
16
T6 t
becoming, you know, a target IVI
of their activities for
17
L1 everv day,
every work i ncr --
dav, working
18
18 0 Wh n
When fo their
you say "a target for

I9
19 activities, " what
activities," do you
what do vou mean?
mean?
02:26 20
02:26 20 A They f 'l 'l owecl me
Thev followed and prepared
me and orepared aa report
i:eoort- on
21
2L me and they investigated
V me, basically. They hired
22
22 riva
private r and
investigators, a fr them in
I caught one of

23
23 front. of
front of mv t, u se -
my hhouse. t-hev put
Anclthey
And re orl. together
out aa report looet-her
24
24 r the Deputy Attorney
for rn General, who read
T the
02:26 25
02226 25 report, vou know -- basicaffv
reoort-, you basically mad â bunch of
made a of

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1
1 accusations against me.
accusations against me.

2 is verv
Vühich is
Which very common T f you
common. If vôlr don't
don I t- have
have aa
3 k the
case, you attack h person bringing the case. It's

4 a very
a verv common
c n tactic.
t-act-ic -
02:27
02:21 5 O
Q Did you
Did bring aa copy
you bring of that
copy of that report?
report?
6 A
A That report? II never
That report? got it.
never got The DAG,
it. The DAG'

71 Lesl-ie Westmoreland,
Leslie Vfestmorelandr refused give it
to give
re fused to it to
to the judge
the judge
8 or decided
or that the
decided that judge didn't
the judge didn't need to see
need to it and
see it and

9 it wasn't
it relevant.. And
wasn't relevant. Andthen the attorney
then the attorney was
\^ias

02:27
02:21 10
L0 at me
screaming at
screaming me in the hallway.
in the Other people
hallway. Other in the
people in the
11
11 hallway you know,
hallway -- you know, law
1aw enforcement never heard
enforcement never heard
I2
12 anything l-ike
anything that before.
like that But to
before. But just --
to just
13
13 bloodcurdling accusations
bloodcurdling in the
accusations in the hallway in court.
hallway in court.
I4
14 I'm letting
I'm you know
letting you that that's
know that pretty common.
that's pretty common.

02:27
02:21 15 O
Q did all
Vühen did
When that happen?
all- that happen?
16
L6 A
A That was
That in the
was in the course
course of the three
of the three years
years
I1
17 of that case
of that that II worked
case that worked on nearly every
on nearly every day.
day.
18
1B Vühen Ir transferred
When transferred to LAX' II had
t.o LAX, to be
had to still on
be still on the
the
19
19 for the
hook for
hook the subpoenas
subpoenas and, you know,
and, you know, the rest of
the rest of
02:21 20
02:27 20 the It was
the case. It was my case. And
my case. soII still
Andso still- had to
had to
2I
21 with Leslie
work with
work for another
Leslie for year.
another year.
22
22 O
Q was this,
when was
So when
So time frame-wise?
this, time frame-wise?
23
23 A
A be -- II could
would be
That. would
That tell you
could tell exactly
you exactly
24 from my
from my resume when II --
resume when 'cause II moved
-- 'cause over from
moved over from
02:28 25
02:28 supervising deport.ation officers
supervising deportation for aa few
of ficers for few years.
years.

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GREGORY MEINHARDT
EXPERT GREGORY
EXPERT - 01/10/2018
MEINHARDT - OL/LO/2078

1
1 of America.
of America.
2
2 O
Q Any
Any of the people
of the peoPle that you've heard
that you've heard
3
3 Ms. Albert believes
Ms. Al-bert are involved
believes are in this
involved in this case that
case that
4
4 you
you bel-ieve
believe were involved --
were involved
02:35
02:35 5
5 A
A Vüere they part
Were they part of my case?
of mY No.
case? No.
6
6 O Have
H ive any expert testimony
you ever given l- in
7
1 the area of
the area of sovereign cítizens?
sovereiqn citizens?
8
B A No. This is
No. This is the fi rst- time
the first I tve been
time I've be en asked
asked
9
9 to do
to it.
do it.
02:36 10
02:36 O
Q you ever
Have you given any
ever given any training to law
training to
11
11 on sovereign
enforcement. on
enforcement citizens?
sovereign citizens?
I2
12 A
A consulting of
The consulting
The law enforcement
of law over the
enforcement over the
13
13 three or
three four years,
or four years, II did that. II had
did that. had to. Because
to. Because
14
L4 there just
there just wasn
wasn't guidance or
't enough guidance or expertise.
expertise. ButBut
02:36 15
02:36 15 the two
the two experts that were
experts that put out
were put out there in the
there in the
16
L6 patrol area, at
patrol area, least, were
ât least, not obtainable
were not obtainabl-e by phone.
phone.
I7
17 They \^Iere
They were given Sig Alerts
given Sig Al-erts to patrolmen around the
to patrolmen the
18
18 country.
country.
I9
19 kind of
That I s kind
That's of how difficult it
how difficult is to
it is to get
get
20
02236 20
02:36 people that are
people that willing to
are willing to come forward or
come forward that
have that
or have
2I
21 experience. These
experience. Theseare just two
arejust patrolmen from
two patrolmen from North
North
22
22 Carolina who
Carolina made aa cottage
who made industry out
cottage industry of, you
out of,
23
23 know, gr_vrng
know, giving seminars to law
seminars to enforcement.
law enforcement.
24
24 Q
O you familiar
Are you with the
famil-iar with the name
name

25
02236 25
02:36 DaryI Johnson
Daryl with the
Johnson with the Department of Homeland
Department of Homeland

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GREGORY MEINHARDT Ot/70/2OIB

11 0 What training do you have on ere


n sovereign

2
2 citi zens ?
citizens?

3
3 MS. ALBERT:
MS. Obiection. Vague
ALBERT: Objection. Vaque and
and
44 q 'l-n
¡ml-l I aflrtìl1 q âas
ambiguous to lr¡ininrr D a\ you
training. Do m 1n where
\74ì u mean r.rl-r a ra ha
he

02:38
02:38 5
tr.
trained others
trained or where
others or he was
where he trained?
was trained?
6
6 BY MS . WALKER:
BY MS. WALKER:

7
7 O
O You can answer.
You can answer.
8B A Ifv
I've had a commitment of 44 years out of a

9
9 n-
22-year career of on-the-job tv learned
training. I've l
'l
02:38 10
02:38 10 it- the
it the wav
way th evr\/e learned
they've earnecl it. Actuall v, every
it. Actually, everv day,
dav,
11
11
II hi or somebody telling
looking at this, ln me
m I
that's an

L2
12 expert, like the primary r
r contact with the Recording
Office, 'ls the
o ffic ê- is ha tor-hni r-e I srrll
technical e r\/t s.)
supervisor. .l-hoqc
So those
So
13
13

14
T4 hr recording, he's
issues with I
the expert.
X He's

02:38 15
02:38 15 and training
tel-lincÌ me and
telling traininq me
me on d ailv basis.
on aa daily basis.
L6
16 MI
Now he goes to a seminar -- like all

I7
17 ra¡rrrrlarq
recorders rln n I I screen
don't c^rôôn f ar fraud
for l'rrr I they
f r=rrrì -- but ll-r arr go
õ^ once
^n
ñô

q f-nrrlÄ IT talk
l:ll¿ :l a seminar
ê ml_ nâr 'l i Þa
18
18 r year
a \7^.âr to
J-n â a â T. Could
a seminar. at ^ like

L9
19 that and
that and educa e t-hem?
educate Sure.
them? Sure.

02:39 20
02:39 20 0 n r -- not
Have you been to a seminar no general

2I
21 enforceme nt t-rainino.
law enforcement
law training. II used
usedto
to be i n that
be in that- area
area
22
22 t1 So
as well. I
i) I'm whatt you're
familiar withhw I
talking

23
23 :krnrrl- But
about. qê mrn â r on
rrl a.â seminar rln sovereign
a rÂ'1 af tì citizens,
r'r ili n c have
h 1T7ô
^\7ô

24
24 volr ever
you at.tend cl one
ever attended one of
of those?
t-hose?

02:39 25
02:39 25 A
A No.
No.

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1
1 BY MS.. VüALKER:
BY MS WALKER:
2 O
Q I don't
I don't mean
mean to rude, but
be rude,
to be but we are on
\^Ie are on a
3
3 limited time.
limited Andthis
time. And is an
this is important question
an important quest.ion Iï
4
4 need an answer
need an to.
answer to.
5
5 A
A Okay.
Okay.

6
6 O n to you is: The vast
So my Question
7
1 f sovereign citizens are not violent. Do
majority of D

8
B \/ôll
you âcfr ê ¡¿'i
agree with lh that
lhel- statement?
st l-amanl ?

9
9 MS. ALBER T: Objection.
ALBERT: Obiection. Misstates
Mis s t-at-e s
02:43
02:43 110
0 assumes fact-s not
ASSUMCS facts not in
in evidence.
e i cìence -

11
11 THE WITNESS:
E h criminal
I don't have the

I2
12 rI
histories for all the sovereign citizens. Their

13
13 potenti I for
potential for violence is enough
violence is enouoh to t r ooer
to trigger a
ra¡ nl i nl iin
n cnmal'rnrlr¡ rFl.rarz I ra Yr/ìq q f 1-ri'l ì l-r¡
14
L4 reaction somebody. They're a.â possibility.

02:43
02:43 15
15 O H n
All of them? Hang on a second. IIwwant to

I6
16 oetac
get I ear --
a clear

I1
17 A You're acting as if there's some club where

18
1B we (lAn
r,^re can id enli fv al
identify allI of
of them Ancl --
them. And

L9
19 o
O Ancl th atts really
And that's rea'l lv the si r; right?
ooint, sir;
t-he point, rioht-?
02:43
02:43 20 There's ot. aa club.
Therers not club. It's not. a
It I not a membershi rl It's
membership. Tt-rs
2L
21 if
really a marker in identification based on a

22 charact.e istic or
characteristic or trait
traít that
th at- someone th t. allows
has that
someone has allows
23
23 you to
vôr1 I b el someone
to label sômeone as a
a sovereign crt-izen or
sô\/erei crn citizen Õr not.
not. -

24 A r actions speak for


Their f T how the word is
02t43 25
02:43 25 used the most.
used the most.

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MEINHARDT -
GREGORY MEINHARDT 07/TO/201.8

1
1 o
0 Ancl because
And because of t hat. it
of that, i t would be very
worrld be verv
2 difficult, t en. to
clif f icult. then, t.o say
sav that
that the sover ei on citizens
t.he sovereign citizens
3
3 ãs aa whofe,
as i s dangerous
whole, is or not
clanoeraôrrs or not dangerous
danoer ôus or
or have a
4
4 propensity in rnnot?
l-n that direction or t
02:43
02:43 Ã
5 A There's nno argument on that. It's
T

6
6 absolutely b en determined
absolutelv been cletermined by
bv the
the FBI, ancl IT think
FBI and think
7
1 evervbod v agrees
everybody adrees that sov reion citizens,
that sovereign citizens, you
vclu know,
know,
8
Õ aread
are est'i e t-errorist
a domestic terrorist ôrcrâ ni z.at i on - You
organization. Y ôr'r know,
know.

9
9
'l nrrqa
loosely. I \7 There
rFl.rara ¡ranll-
aren't -A rd ¡¡rrrzi
card carryingnn maml'r r ô But
members. Rrrt

02:44 10
02:44 1-0 as qro Ð, as
as aa group, as they're de 'i necl, they
thevtre defined, t-hev are
are dangerous.
ncJeroÌts.
11
11 rlìha T ê iis
There q no âarguing
rdll f Tlaf int r{-
in that. Änr¡ patrol
Any rT ¡l T I cop
^^n fhrJ-
that

I2
12 vôu t-alk to
You talk to out
olll there
lhere croi no to
as going
is lo tell v ônt that.
tel I you h at

13
13 O
Q Okay. Let's go
Okay. Let's goahead
ahead and turn to
and turn to --
I4
14 MS.
MS. WALKER: Let's mark,
WALKER: Let's markr as next in
âs next line,
in line,
02:44 L5
15 Ms. Albert's
Ms. trial exhibit,
Albert's trial exhibit, which
which happens to be
happens to
L6
16 pubtished
published by the Department
by the of Homeland
Department of Security.
Homel-and Security.
17
T7 Trial Exhibit 50.
Trial- Exhibit AndII think
50. And think we're on 3.
l^Ierre on 3.
18
1B (Exhibit 33 was
(Exhibit \^Ias marked
marked for identification
for identification
I9
19 is attached
and is
and attached hereto.)
hereto. )
20 BY MS.. VI]ALKBR:
BY MS WALKER:

2I
21 Q
u and take
ahead and
Go ahead
Go a peek.
take a It's aa multipage
peek. It's multipage
22 document . Have
document. youseen
Have you this before?
seen this before?
z5
23 A No,
No, II have
have not. This one
not. This is from
one is from
24 February 2000-
February 2000- I mean, 2015.
I 2015. I at LAX.
I was at LAX. We
We

02:45 25
02:45 25 didn't have
didn't time to
have time stuff like
read stuff
to read this. II am
like this. am a

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EXPERT _ 01/10/2018
GREGORY MEINHARDT -
EXPERT GREGORY OI/IO/2078

1
1 OSo
O So here's
here's my quest.ion-- here
my question here isis an
2
2 admonition I'll give
that I'll
admonition that give you. I'm taking
you. I'm t.aking aa
3
3 deposition
deposition. . So it's not
Soit's l-ike aa coffee
not like coffee conversation
conversation
4
4 where
where -- even though II appreciate
even though appreciate and II respect
respect --
02:49
02:49 5
5 and Irve seen
and I've your resume,
seen your resume/ you you have
have aa lotIot ofof
6
6 information to
information to give.
give. But I 'm on
But I'm on aa tight
tight timeline.
timel-ine.
7
1 And so II have
And so have very specific questions
very specific questions thatthat II need
need
8
B ans\^IerS to.
answers to.

9
9 A
A Okay.
Okay. So youasked
Soyou asked me to read
me to read that
that. and
02:50 10
10 I've read
I've read it.
it. "Most citizens are
sovereign citizens
"Mostsovereign are
11
11 nonviolen
nonviolent. t. And this assessment
Andthis assessment only applies to
only applies to
12
72 those that
those use violence.
that use violence." "

13
13 O
a) Do \/aìll
you agree
â af rêê ô -t .l
or AS â af rêê
disagree with
I^7'1 hl that
h :l

14
L4 statement ?
statement?

02:50 15
15 A z NS are
That most sovereign citizens
'l
16
L6 nonvi ent-?
nonviolent?

17
L7 O Right.

18
18 A
A I disaqree
I with that.
disagree with that.
L9
19 O h
So that statement, you disagree? And your

02:50 20
20 _rnl
opinion is that most sovereign citizens
a are violent?
T

21
2T A Have some -- are violent or h
have a

22
22 r
propensity fviviolence, yes.
of

23
¿-J o
O cl what
And what do vou hase
clo you base that- on sir?
that on, s I 7?

24
24 A n
That ones I've had contact with.

02:50 25
02:50 25 OAn
O t.hose people
And those oeoole were criminals; right?
\^rere criminals; ri clht.?

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EXPERT GREGORY MEINHARDT -
EXPERT 01,/70/2OIB

1
1 A
A Well-, êrre makino
Well, we're making criminal c ses against
criminal cases aoainst
2 them.
them.
3
3 O
^v Riqht.
Right.
4
4 A Most sovereign
V T h
citizens do have
_l- criminal

02:50
02:50 J5 backorou cls
backgrounds. There's
- so thincr in
There I s something in their
their history
hi storr¡ --
6
6 o
O And
And w t clo
what you base
do vÕr1 base that
that off
off? That most
? That most
7
1 c i t'i zens have
sovereiqn citizens
sovereign crimin I in
have criminal in their
their
8
B backqround?
background?

9
9 A
A So V e r e l- .rn citizens,
Sovereign cilizên.q- âs I
as renre qonl- them
I represent thc m --

02:50 110
0 n as I -- not represent
I mean, T them -- as
S I

11 rrnrlarcl
understand¡ îrô living
h õm -- are I i van ñ outside
nrr1-q'i rla of
af the
I h ô rules.
rrr'l ac
11 ^+ them
12
L2 And that usually
And that usrrallv leads t ô aa record
Ieads to record of
of some
so me sort.
sort- -

13
13 O Do you agree
T with
w I l-e
this article, that there

14
74 r
are sovereign citizens, and r sovereign
n then there are

02:51 15
02:51 citi zen extremists?
citizen Doyou
extremists? Do v o11agree disa ree with
or disagree
aOree or with
I6
16 that statement?
that statement?
17
L1 A
A No. ITthink
No. ihink sovereign ci t. i zens are
sovereion citizens are
18
1B extr .ì st-s -
extremists.

I9
19 O
O AII of them,
All of is your
t-hem, is oninion?
vour opinion?
02:51 20
02:51 A A
As I know them, yes.
5

2L
21 o
O ok v. And
Okay. Andwhen vo u say
whenyou sav "as
"as II know t-hem, tt
kno them,"
22 I ones you've come into
is that because the only l-

23
23 contact it-h have
contact with have been cr imina f s ?
been criminals?
24 A
A TI think
I hinÞ all qnrraroi dn citizens,
r'l I sovereign ri1-i'za n q as I| define
.{ôf r nô

02:51 25
02:51 rl-
them, are criminals. t
If you're living outside the

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GREGORY METNHARDT 01./1'O/2OLB

1
1 rules, you're
rules, â criminal.
vou t r a eriminaf
2
2 OQ So
So ifif you
you d.on't obey aa court
don't obey order, if
court order, if you
you
3
3 live outside
live outside of of the civil- law,
the civil you're aa criminal?
law, you're criminal?
4
4 AA If you are
If you are directJ-y trying to
directly trying t'o subvert civil-
subvert civil
02:51
02:51 5
5 law, then
law, then you are engaged
you are engaged in in criminal activity, yes.
criminal activity, yes.
6
6 O
Q And that
And that makes You dangerous?
makes you dangerous?

7
7 AA That can'
That can, Yes.
yes.

U8 O
Q Are you
Are you aware that Ms.
aware that Ms. Albert has been
Albert has been

9
9 dísciptine
disciplined d byby the state bar
the state bar for failing to
for failing to follow
fol-Iow
10 at
02:51 10 l-east four
at least four court
court orders?
orders?
11
11 A
A Ms. Albert
Ms. Albert --

12
L2 MS. ALBERT:
ALBERT: Objection. Actually misstates
Ob j ectíon. Actually misstat'es
13
13 the facts.
the facts.
I4 BY
14 MS.. WALKER:
BY MS WALKER:

02:52 L5
15 O
Q Might be
Might ive. Are
be ffive. you aware
Are you that' she's
au/are that she's
L6 been
16 discipl_ined by
been disciplined by the state bar
the state bar for failing to
for failing to
17
L7 follow several
follow court orders?
several- court orders?
18
1B A
A I'm aware
I'm a\^Iare of the state
of the state bar,
bar, and I'm aware
and I'm aware
19
19 that
that she told me,
she told and II asked
me, and her about
asked her it -- and
about it and
more recently,
20 more
02t52 20
02:52 recently, today, asked her
today, II asked about it.
her about I'm
And I'm
it. And

satisfied that
2I satisfied
21 the bar
that the has, you
bar has, you know, administrative
know, administrative
22
22 procedure
procedures s t.hat they go
that they go through.
through. And that doesn't
And that doesn't
ZJ make
23 guilty' necessarily,
everybody guilty,
make everybody necessarily, that that they've
they've
24 accused
24 accused of activities --
disciplinary activities
of disciplinary
02:52 25
25 O
Q You're
You're aware that they
aware that they had
had to actually
to actually

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BXPERT GREGORY MEINHARDT -- 01/10/2018
GREGORY MEINHARDT 01./IO/2018

1
1 MS . WALKER:
BY MS.
BY WALKER:

22 O
O Do you
Do believe that
you believe that or
or not?
not?
3
3 MS. ALBERT:
MS. Objection. Hearsay.
ALBERT: Objection. Hearsay.
44 WITNESS:
THE WITNESS:
THE conducted aa seminar
-- conducted seminar-- you
you
A'. Etr
02:55
VL,JJ 56 asked me
asked me about that -- on
about that on this, you know,
this, you knowr on their
on their
66 involvement in
involvement law enforcement.
in law it's
And it's
enforcement. And all
all
71 time and
their time
their all their
and all effort and
their effort the whole
and the whol-e

8B the whole
seminar, the
seminar, whole conversation is strictly
conversation is strictly about
about
9 child porn.
child Therewas
porn. There nothing offered
wasnothing by that
offered by that
02:55 10 that would
company that
company allow me
woul-d allow to answer
me to your question.
ans\^Ier your question.
11
11 MS. WALKER:
MS. WALKER: Motion to strike
Motion to strike as
as

I2
12 nonresponsj-ve.I'm
nonresponsive. goingto
I'm going to take quick break.
take aa quick break.
1')
13
-LJ (Recess taken.)
(Recess taken. )
I4
14 BY MS . WALKER:
BY MS. WALKER:

03:14 15
03:14 15 O r
Mr. Meinhardt, a ree that not all
do you agree
I6
16 q.ì\rêrai rrn citizens
sovereign r-)li ze e are
î rô dangerous?
rlrnnrarnrrq ?

I1
17 A
A No.
No.
18
1B O
O Okav.
Okay.
19
L9 Ttltr COURT:
THE í-ÕIIRT. The
Tha answer lo that
âñs\¡rêr^ to lh¡l is
i s no?
n 6?

03:14 20
03:14 20 THE VüI
THE TNESS: That
WITNESS: 'i e. correct.
h¡ t is r-nrrer-f

2I
21 BY MS . WALKER:
BY MS. WALKER:

22
22 O
O vour opinion
So your
So is that
opinron is all sovereign
t-hat- all sovereion
23
23 citizens pose some
citizens pose danger?
some danger?
24
24 A
A Yes.
Yes.
03:14 25
03:14 25 O
O What's that opinion
What's that oninion based on?
on?

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MBTNHARDT - 07/LO/2078

1
1 A
A Tl-lq
It's lrêrqnn¡l
personal êr. ar'ì an¡a
experience r^ri{-l-r
with mrr'l'l-inla
multiple

22 subiects over
subjects ove many \/eâ rs -
mân\/ years.
3 O
Q you understand
And you
And that Exhibit
understand that Exhibit 33 -- II
44 you the
showed you
showed report issued
the report by the
issued by the Department of
Department of
03:15 5q Homeland Security,
Homeland your former
Security, your employer-- disagrees
former employer dj-sagrees
66 with that
with that opinion?
opinion?
71 A
A And II tried
And tried to
to tell you, II write
tell- you, write those
those
8B things. I've worked
things. I've workedat headquarters, and
at.headquarters, they would
and they would
99 ask me
ask for my
me for my opinion on t.hat.
opinion on It's one
that. It's individual
one individual
03:15 10 right there
it's right
and it's
and in what
there in what you've pointed out
you've pointed out to
to
11
11 me.
12
L2 ô
O Õ k â \/
Okay. Anrl so
And e.ì this
lh i e idea
i Äa¡ that
lÞrr.l- 'l-hara
there ârô
are e^mô
some

13
13 people that you might say have marker of a
h v markers

14
L4 citizen, vet
sovereiqn citizen,
sovereign thev lust
vet they iust do what we
do what we would
would
03:15
03:15 15 call paper
call t ê\/ play
annovances, they
ÐaÐer annoyances, n'l ar¡ on
ôn the
the Internet,
Tnt-ernet..
I6
16 thev file
they fi le liens,
l'ì ens. yet
vet- they never try
t-hev never trv to
to harm
harm anyone,
anvone,
17
L1 do you agree that is a type of sovereign citizen, or

18
1B fieve all
do you believe al- of them are the type that would

I9
19 trv and
try harm someone?
and harm someone?

03:15 20
03:15 20 A That is harming someone.

2I
21 O
O Okav.
Okay.

22
22 COURT : Well,
THE COURT:
THE phvsicallv harm.
Vüel-l-,physically harm.
23
23 THE WITNESS:
THE It physically
WITNESS:It oh vsieal-l v harms
harms them.
them-
24
24 I'm talking
I'm talkinq triple bypass surqerv.
tripl-e bvpass Stress to
surgery. Stress to the
the
03:15 25
03:15 25 ooint where
Point where they
thev want to kill
\^Ian to ki l l themselves.
t-hemselves -

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1
1 THE COTIRT:
THE All right.
COURT: All ricrht- I'm ta t Þi nrr about
Tr m talking :l-rnrrt
2
2 rm ln
physical harm ki of
in terms of assault. Some kind
3
3 as s ault i ve behavíor.
assaultive all sovereign
Are all
behavior. Are sovereicrn citizens
c-r 'ì Tens --

4
4 THE WITNESS:
THE WITNESS: That assaultive behavior
Thatassaultive behavior can
can
03:16 5
5 proqress
progress from that behavior.
from that absol-utelv.
behavior, absolutely.
6
6 THE COURT:
RT But do you believe hat all
V that

7
1 sovereign r:i t i zonq - anybody
q ô\/ê re a crn citizens, ¡nrzkloclr¡ that ar:cenl- q that
lhet accepts lh¡l I el^re I
label,
8
B is r-:n¡kr 'la of
i e capable n h r¡qi r'¡l I r¡ assaulting
nf physically ^eairr'll-inrr lhoi
theirt enemy?
anamr¡?

9
9 A Ye.s
Yes.-
03:16 10 THE COURT:
THE that is
Sothat
COURT: So your -- I'm
is your going to
I'm going to
11
11 retreat now.
retreat I'lI go
MaybeI'll
now. Maybe go and first
the first
reread the
and reread
12
T2 in l-imine.
motion in
motion There's only
limine. There's ive vol-umes.
only ffive Maybe
volumes. Maybe
13
13 it will
it will all
all become cl-ear on both
clear on both sides. I'll just
sides. I'll j ust

14
L4 l-et you
let go ahead.
you go ahead. We're going to
Vüe'regoing go to
to go to 4:30
4:30 p.m.
p.m
03:16 15
03:16 15 Vüe'll
We'll see where we are.
where we are. We're going to
We t re going to march
16
L6 here in
forward here
forward in some kind of
some kind deliberate fashion.
of deliberate fashíon.
I1
17 February lst, we'll
February 1st, start wherever \^/e
we ' l-l- start are .
we are.
18
1B MS.
MS . VüALKER: Thank you,
WALKER: Thank You, your Honor .
Your Honor.
t9
19 BY MS.. WALKER:
BY MS WALKER:
03:17
03:11 20 O
Q Okay. II want
Okay. \^Iantto turn to
to turn your report,
to your report, which
which
21
2L I have
I have a copy of.
a copy AndII think
of. And think -- the
the other
ot.her one that
one that
22
22 you
you have in front
have in front of
of you, is that
You, is your only
that your only copy?
copy?
23
ZJ A
A Yeah.
Yeah.
24 . WALKER:
MS. soI'm
And so
WALKER: And
MS going to
I'm going to mark that
mark that
03:17 25
03:17 25 as Exhibit 4.
as Exhibit it's entitled
Andit's
4. And entitled "Expert report of
"Expert report of

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MEINHARDT -
GREGORY MEINHARDT OL/LO/2OTB

1
1 Gregory Meinhardt.
Meinhardt." It's aa -- it's
" It's not paginated,
it's not paginaLed,
2
2 but it's
but it's aa quarter
quarter inch
inch thick
thick or
or so. Itrs a
so. It's
3
3 mul-ti-page
multi-page document; right .
document; right.
4
4 (Exhibit 44 was
(Exhibit was marked
marked for identification
for identification
5
5 is attached
and is
and attached hereto.
hereto.) )

6
6 THE WITNESS:
THE YES.
WITNESS: Yes.
7
7 BY MS.. WALKER:
BY MS WALKER:
8
B O
Q Is this the
rs this report that
t.he report that you
You were
9
9 referencing earlier
referencing in the
earlier in that you
deposition, that
the deposition, You and
03:17 10 Ms.
Ms. Albert. prepared together?
Albert prepared together ?
11
11 A Yes.
Yes.
I2
12 O
Q going to
So going
So to -- if just count
if II just the pages
count the Pages
there appears
13 there
13 to be aa timeline
appears to kind of
timel-ine -- kind in aa --
of in
I4 some
14 type of
some type system-- the
of box system first several
the first several pages.
Pages
Do you
15 Do
03:18 15
03:18 see what
you see what I'm referring to?
I'm referring to?
I6
16 AA Yes.
Yes.
I1
17 o
O Who nut
Who that timeline
put that t'imeline together?
tocrether?
18
1B A
-¿{ Ms Al bert out
Ms. Albert t he timeline
put the t.imeline together.
to crether -

I9
19 O I --
Okay. And you've accepted that as
03:18 20
03:18 20 C rrr¡t ô
accurate, in aì r rìa L to
1 t'ì order t ^ form
fnrm \/^r'ì TOopinion?
your tht^n/
^(1

2L
21 A s accurate,
As â eerr rat-e , yes.
\/e.q -

22
22 ô
O ft ka
Okay. n'i rl you
Did arr 1ê a J- i nn her
\rnr r Question l-rar about ll-r¡l-
-¡l-rnrrl that r1-
at

23
23 all ?
all?
24 A Yes. We
Ye inlehad conve rsations on
haclconversations on every
eve v item.
item-
03:18 25
03:18 25 O ku
An did you ask1. her for any backup
Okay. And

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GREGORY MEINHARDT 07/TO/2078

1
1 document?Or
document? did you
Ordid voulust her verbal
accept her
rust accept verbal-
2
2 responses ?
responses?
3
3 A h provided
She T l_ documents on -- not on, you

44 know, evorvthinq.
know, Butshe
everything. But provided substantial
she provided subst.antial-
03:18
03:18 5R documentation a cl her
documentation and her accounts.
âeeount..s -

66 Q
O Okay. And
Okay. Andso if you
soif you move past the
move past the
7
1 timeline, at
timeline, the bottom
at. the of that
bottom of that timeline
timeline box, rt
box, it
8o() indicates there are
indicates there some depositions.
are some It says
depositions. It says
9
9 it starts
deposition -- it
deposition with the
starts with the deposition
deposition of
of
03:19 10
03:19 Monica Jones.
Monica Jones. Do you see
Do you that? I'm
see that? on -- II guess
Irmon guess II
11
11 woul-d say
would L, 2,
say -- 1, 2 page 4?
33 -- page 4?

I2
12 A August 6th?
August 6th?
13
13 O aft-er that
So after
So that- box
box area
area of
of that
that timeline,
timel-ine,
14
L4 h r I
there's I
1, 2, 3, 4 people -- there's four things

03:19 15
03:19 notated. It starts
T wa h the
with the deposition of Monica
L6
16 Jones. You
Jones. s e where
Yousee whei:e II am?
am?

17
T1 A
A Yes.
Yes.

18
1B tt
O Dicl you
Did vou write
write that
tha f or
ôr did
cl'i cl Ms.
Ms- Albert?
Albert?
I9
19 A
A This right
This riqht here?
03:19 20
03:19 20 O Yeah. Deposition of Monica Jones.

2L
21 A IT don't
clon I t- recall.
recaf l.
22
22 O
O Do vou know
Do you wh at- that
know what even means?
t-hat- even means ?

23
23 A These are
T eah These are supporting
-- yeah.

24
24 documents for h bottom, that
she put these on the

03:19 25
03:19 25 she provided
she orovided me
me with. An clwe
with. And \^reagreed t-hat this
acrreecl that this was
\^Ias

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GREGORY MEINHARDT OL/LO/2OIB

11 to be
to be reviewed.
reviewed.
2
2 O Okay. So she wrote down this deposition of

3
3 Monica Jones?
Monica Jones? She tvped that?
Shetyped that?
44 A
A wrote this
She wrote
She timeline. II asked
this timeline. her to
asked her to
03:19 tr
5
J wri-te the
write the timel-ine out. II looked
timeline out. at it.
l-ooked at And, you
it. And, vou
66 know, don't really
know, IT don't reallv recall
re all the
the details
cletails of,
of. you
vÕrl

71 llrrnrrrvh
l¿n ar^r -- through
know our ñ^n r c¡J- a ^ñ were
/'ìrrr conversation, 1.7ô rô r.rô put
we nr ll- the
I l-r a

8B report tooether. And


reþort. together. the n there
Andthen t-here was
was some back and
some back and
9
9 f ort-h, you
forth, vou know.
know. Much l 'i ke an
Muchlike ân editor,
ecli tor. IT guess.
cJìress -

03:20 10 ô
O ôÞrr¡
Okay. And \7.rrl r understanding
Ànrì your tl nder o ta nÄi n¡ was
r^t¡c the
lÞra I i c'l-
list

11
11 here are documents
here are documents that .t^rere supporting
t.hat were strnoort-rncr -- were
\^/e f e

12
L2 to support
srrooosed to
supposed suþr:ort your oni ni ons or
vour opinions ôr the
t.he timeline?
timeline?
13
13 A IT think
rh.i nk this
I h a q is rrJ- of
-LS part n€ this
{-l-ri c list
I i c1- that
l-]'rrf
^
I4
14 continues on the
continues he next
next- page.
Ðaoe -

03:20
03:20 15
15 ô
O An .lq so
And lm asking
oI I'm ¡e.kinrr you:
f l lnTl-r¡l- is
What ic this
ì-hi<r list?
liql?

16
L6 A^ So
Qn these
l- l'laqa are
â râ r I fn documents
supporting
arrrllr^ do ¡rrmanl- c for
Far .l-l-ro
the

t1
17 oþr_nr-on.
opinion.

18
1B ô
O Okay. Sndid
ô ka \7 So .l'i .ì you
\/.rrr review
r arri ar^r the
lha avrrarl-
expert rô?lrì r I
report

19
19 of Walter
of Hackett?
Wal-ter Hackett?
03:20 20
03:20 20 A
A II believe
believ e that
that- II did.
did-
2I
21 O
tt An .ì do
And rìn you rêra ¡l'l
\/ôll recall r^rl.r¡ì- it
what i+' is
ic that
llrrl

22
22 Mr. Hackett
Mr. ni necl about?
Hackett opined aborrt-?

23
23 A
A II don't.
don't.
24
24 O
u Are you
Are you aware
aware that Mr. Hackett
that Mr. Hackett is friend
is aa friend
03:20 25
03:20 25 of Ms.
of Ms Al-bertrs who
Albert's who was al-so disciplined
h/as also by the
disciplined by the

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GREGORY MEINHARDT -
EXPERT GREGORY OT/70/2OIB

1
1 to opine
assigned to
assigned opine about
about the four things
the four things enumerated
enumerated
2
2 under the task
under the task section?
section?
3 A
A Yes.
Yes.
4
4 O
C) Ancl th
And n it
then says tton'i
ìl sâ\/s niôn-tt
"opinion." And I t says,
ncl it .sâ\/s -

03:22
03:22 5
5 ItYes - Yes.
"Yes. Yes - tt DoI)ôyou
Ye s - Yes." see that?
votl see lh:t"

6 A Yes
Yes.-
7
7 O tv indicated
And so I'm assuming, since you've
8B before that Ms. Albert had the h
h typing skills, that

9
9 ha
u didn't type that?
You
I f-¡rrca
03:22 I0
03:22 10 A
A lrïa
No. Q1-rahelped
She r^ri l-h the
m ê with
l-ra'l narl me l-Þra l-rzrr
typing.
l_n af 'Cause
11
11 it \^Ias
it it-e aa pressed
was Quite t e frame.
Ðressed time frame.
12
L2 O
O Okav.
Okay.
13
13 A So she helped m n
me with the typing, and I
14
T4 k
edited and asked A
for reviews over the phone. And
03:22 15
15 then we
then a rr i vecl at
we arrived at the renort- -
the report.
I6
16 Q
(J Okay. And
Okay. Andso yourfirst
soyour first opinion,
opinion, do
do you
I1
17 agree that
agree first opinion
the first
that. the is "yes"?
opinion is "Yes"?
18
1B A You
You mean as in
mean as relation to
in relation no. 11 there?
to no. there?
19
L9 what sovereign
" ExpIain what
"Explain citizens are"?
sovereign citizens are"?
03:23 20
03:23 20 Q
O I don't
I know, sir.
don't know, this is
Sothis
sir. So your report;
is your report;
2I
21 right ?
right?
22
22 A Yes
Yes..
23
23 Q
O So after
So opinion, itit says,
after opinion, says, "Yes. Yes.
"Yes. Yes.

24
24 Yes.
Yes."" Do yousee
Do you where II am?
see where am?

03:23 25
03:23 25 A Yes.
Yes.

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GREGORY MEINHARDT - OI/LO/201.8

1
1 A
A Yes. Andthere
Yes. And wouldn't be
there wouldn't no. 44 if
be aa no. if
2
2 there
there wasnfL
wasn't a privacY issue.
a privacy issue.
î3 O
Q And
And no. 4, sir,
no. 4, sir, says, "Did Ford
saYS' "Did Ford Credit,
Credit

44 Company, LLC
Company/ LLC put Ms. Albert
put Ms. Albert atat substantial ris k of
subst.antial- risk of

03:31
03:3i 55 harm by
harm communicating with
by communicating informant and/or
with an informant and/or
6
6 Monica Jones?"
Monica Right?
Jones?" Right?

17 A
A Taking
Taking what she told
what she told rrr€
me, that they
r that they
o
8 information about
communicated information
communicated about her, does that
her, does that put
put
9
9 her at potential
her at potential harm? Yes. It
harm? Yes. It harms her when
harms her when herher
03:31 10
03:31 information is distributed.
inf ormat.ion is distributed.
IL
11 O
Q Okay.
Okay. So Soareareyou trying to
you trying tel-I me
to tell that
me that
I2
12 the reason
the there is
reason there is only three yeses
only three yeses isis because
because thethe
13
13 last yes
last applies to
yes applies to both
both 3 3 and
and 4?4?

I4
14 A
A I told
I totd you twice already
you twice that there
already that there is is some
some

03:31 15
03:31 15 grammar typing errors.
grammar and typing There should
errors. There should be four
be four
16
L6 yeses there.
yeses there.

I1
17 O
Q Okay.
Okay. ButButletlet me turn to
meturn to the next page.
the next page.
18
1B Skipping the
Skipping qualification section,
the qualification because II have
section, because have

I9
19 reviewed your
reviewed CV, it
your CV, it states
states "opinion.
"opinion." " And if you
And if you
03:32
03 20
32 20 just follow
just follow along
along with
with me for aa second?
me for second?
21
2L A
A Okay.
Okay.
22
22 aì
O tr Tn ñ\7
"In /-lñ1 1.ì'ì aì n
my opinion, Enr
Ford Mnlnr
Motor f-nmrr¡nrz
Company, T.T.fì nr
LLC putr l-
^
23
23 Ms.. Al-be
Ms Albertrt. at
at- risk
risk of ha rm bv
of harm communicat i no wit-h
by communicating with
w
24
24 Monica Jones." Let me stop there for a minute. How

03:32 25
03:32 25 did Ford Credit
T ir
put Ms. Albert
T rm by
at a risk of harm

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- 01/10/2018

1
1 communicating w'i th Monica?
communicatinq with Monica?
2
2 A Th
They communicated with somebody
o other than
3
3 Ms. Albert. They communicated with these three
4
/1
T n IV
individuals. And it's lust
q
my opinion that they put
03:32
03:32 q
5 her
her at- risk hr¡
at risk by cclmmuni catino with
communicating 1-hem -- bv
with them by
6
6 communicating
].N with them alone. We
\^It Vü o
don't really know

7
1 what they to
what t.hev I cl t-hem
told or sure.
them ffor sure. \^Ie renrt there.
Vüe weren't
We there.
o
8
(J tk to them at all.
But they should not have talked

9
9 That's what m n that they did
my opinion is based on,

03:32 10
10 put her at
put her risk.
at risk.

11
1_1 o
O So i t doesn't
So it matt r to
cloesnrt- matter f o you
vôìr what w âs said.
what- was sâ l- cl-

I2
12 If redit had
If Ford Credit conve rsation with
had aa conversation with Monica
Moni ea Jones,
,Tones,

13
13 \/^rr
you hal'i ôrzô
believe l l'l ll-
that alt l I .l put
would
\^I nrrl- Mc Â'l l'ra r I at
Ms. Albert I risk?
r'i cl¿2

14
L4 A
A ôf course
Of ^^rrreâ
'ì t' m¡llo
it ra
matters r^rhll-
what ll'rar¡
they a^said.
I RrrJ-
But
^
03:33 15
15 hrr aìnrnmrrrr I .a a {-'i nn with
by communicating r.ri l1¡ them,
ll-rom I he \/
they .ìi
did nrll- her
put har -rJ-
at

16
L6 risk.
risk.

I1
17 O
O In what
In what wav?
way?
18
1B A Th
They're communicating h tr
an with her, and they're

L9
19 lininformation.
communicating about her personal

03:33 20
20 O rS
And what personal n do you
information o

2t
21 believe Ford Credit communicated
n_L with Ms. Jones

22
22 about ?
about?

23 A I don't
I believe it
don' believe it matters to the
matters to sÐecific
t-he specific
24
24 piece of information. But the fact that -- lust by

03:33 25
03:33 25 the fact
the tha t- they're
fact that thev're communicating eoardino her
cornmunicatinq regarding her

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- 01/10/2018

1
1 ¿.råqê alone
case ¡ln rrrrl-q her
^ is -- puts h ê T at
¡t rì cl¿
risk.
2
2 t)
O An rl ¡^rlrr¡
And why do rln you ri
l-lo ê
\7/'ì1r believe I h ar¡ | ra
they're
3
3 /-\Ïn Ïn ll l_ ¡rli
communicating nrr about
l.rnlr.|- her
l.lar case?
n¡ <a?

4
4 A Whv do II believe
Why do lre I i erre --

03:33
03:33 (
5 O
O Yeah.
Yeah.
6
6 A rh t -- because
-- that Ms. Albert's
because Ms. Albe trs done
clone a
7
1 zrra1-lrz crnnrl lob
pretty good i nl-r of
n€ relaying .|-n rnâ
ral r.zì nrr to h ê T concern
me her õ^h^ôrn rl-rnrrl
about

8
0 her informat ôn and
her information and conversations
conversations.. he showed
She showecl me
me

9
Y t
phone logs h T information, you
and, you know, other

03:34 10
10 know,
know, about tha I conversation.
about that ccln\¡ersat-ion -

11
11 Q
O So you
So did review
you did Credit's phone
Ford Credit's
review Ford phone logs?
logs?
I2
12 A She showed
She me some
showed me some of Ford's phone
of Ford's logs, as
phone logs, âs
13
13 they've relayed them
they've relayed to her.
them to her.
14
T4 Q
O So you ' ve reviewed
So you've the portions
revie\n/ed the of the
portions of the
03:34 15
15 phone logs that
phone logs that Ms. Albert showed
Ms. Albert showed you?
You?
L6
16 A Yes.
Yes.

I1
17 O
Q Okay. And
Okay. Andyou also reviewed
youalso Ms. Jones's
reviewed Ms. Jones's
18
18 deposition transcript, you
deposition transcript, you said?
said?
L9
19 A
A Her deposition?
Her Yes.
deposition? Yes.

03:34 20
03:34 20 O
Q Did you
Did you review her declaration
review her declaration as
as well?
well-?
2L
21 A
A Do you have
Do you it?
have it?

22
22 O
Q I do.
I do.
23
23 (Exhibit 55 was
(Exhibit was marked identification.
for identification.
marked for
24
24 and is attached
and is hereto. )
at.tached hereto.)
03:35 25
03:35 25 THB VüITNESS:
THE Yeah.I I did
WITNESS: Yeah. did review this one.
review this one.

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EXPERT GREGORY
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MEINHARDT -
GREGORY MEINHARDT OL/IO/2OLB

1
1 with
with all all- the facts, I'm
t.he facts, posing aa hypothetical.
I'm posing hypothetical.
2
2 A
A Sure.
Sure.
3
3 O
Q I'm saying:
So I'm
So saying: AssumeAssume thesethese are are the facts.
the facts.
4
4 Don't take
Don't take my word for
my word just assume
it, just
for it, assume that that they're
they're
03:36 5
5 the facts, like
the facts, like Ms. Albert gave
Ms. Albert gave you facts.
you facts.
6
6 A
A Okay.
Okay.

7
7 O As
O sume that
Assume lhat Monica Jones communicated
Monica Jones with
colnmu ni cat-ecl with

8
B E-n r .l Credit
Ford Cra i l-- because
1-rar-:rrqa she r¡I c letting
eha was lal-1-inrr fham
them k ^r^7 where
know r^rlrara

9
9 Ms. Albert's r vehicle wwas. That she independently

03:37 1100 b
knew where the vehicle was because she had a former

11
1_1 relation shio with
relationship with Ms.
Ms. Jones or Ms.
Jo nes -- or Al- bert- and
Ms. Albert
12
L2 h
knew other people that had a relationship with

13
1-3 Ms. bert-.
Ms. Albert.

t4
14 7\nÄ she
And nJ- ¡ ¡'l-aÄ
qha.' contacted E'nrd Credit,
Ford l-rorl i I nn{- the
not l-1'ra

03:37 15
15 \^I A \r around,
a'l-ha f way
other rrnrrnrl a n df that
and r{- she
cl'ra said,
<¡irl ttr ç you're
"If rzarr I ra

L6
16 f r her car, I kn
looking for know
w where it is." Do
Do you

17
L7 h
believe that that n with Ms. Jones would
communication \^I

18
1B put Ms. Albert at risk
T of harm?

19
79 A Not s you've
Not as relaved itt_ -- your
vou I ve relayed vour
03:37 20
20 hr¡nnthct aca
hypothetical. 'l
NTnl-as
Not \/ôr'l tv ê relayed
â q you've rel avecl it 1- h ¡t
if that w â\/-
way,

2I
21 no.
no.

22
22 O
Q Okay. Areyou
Okay. Are youaware that Ms.
aware that Albert had
Ms. Albert had a
23
23 relationship with
relationship Cindy Brown?
with Cindy Brown? A prior
A prior
24
24 relationship.
relationship.
03:37 25
25 A
A Define "relationship."
Define "relationship. "

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EXPERT
EXPERT GREGORY MEINHARDT -- 01/10/2018
GREGORY MEINHARDT 07/LO/2018

1
1 are looking into
people looking
are people your online
into your online activity. They
activity. They

2
2 sit next
sit you at
to you
next to at the
the bar. Whatever they
bar. Whatever they do. Yes.
do. Yes.
3
3 That's not
That's not any kind of
any kind of unusual you're talking
when you're
unusual when t.alking
44 about sovereign
about cit.izens.
sovereign citizens.
04:18
04:18 5q BY MS . WALKER:
BY MS. WALKER:

66 O
Q Let me
Let take a
me take minute to
a minute to consult. Off the
consult. Off the
71 record.
record.

8B (Recess taken.)
(Recess taken. )
99 BY MS . WALKER:
BY MS. VüALKER:

04:25 10
04:25 10 o
O Mr. Meinhardt,
Mr. Meinhardt, do vôu have
do you have any
ãnv information
informat-ion
11
11 that Ford
that Credit- knew
Forcl Credit whet her or
knew whether ôr not Moni ea Jones,
no1- Monica ,Tones,

12
L2 Cindv Brown,
Cindy ôr Sheri
Brown, or Sheri Moody
Moodv were
\^rere sovereign ei t'i zens?
sovere i crn citizens?
13
13 A DoII have any information that -- cann you
Do

I4
14 sâv it
say i1- aoain?
again? IT kind of lost
kind of I ost \/ôu
you. Sorrv-
- Sorry.
04:26 15
04:26 15 O
O I'm fo eusino on
I'm focusing on Ford
Ford Credit's
Creditts knowledge
knowl eclcre

I6
16 A
A Okav.
Okay.

17
r'7 O Irm wondering if you have any
and I'm

18
1B information that Ford
T r irk knew whether any of
Credit

L9
19 these peopl-e we've
these people we've talked
tal-ked about
about were sovereiqn
\^/ere sovereign
04:26 20
04:26 20 citizens ?
citizens?

21
2T A
A No.
No.

22
22 O
Q And going back
And going to your
back to oprnron in
your opinion your
r-n your
23
23 report -- II think
report it was
think it Exhibit 44 --
was Exhibit it
whatever it
-- whatever
24
24 that was
\^ras that
was was your report -- under
your report under "opinion,"
"opinion, " where
where
04:26 25
04:26 25 it talks
it t.alks about
about Ms. Albert being
Ms. Albert risk of
at risk
being at of harm
harm by

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EXPERT
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GREGORY MEINHARDT OI/LO/2078
MEINHARDT -- 01/10/2018

1
1 with Monica
communicating with
communicating Jones, and
Monica Jones, it goes
and it goes on
on to
to
22 say Sheri Moody
say Sheri and Cindy Brown.
Moody and you familiar
Are you
Brown. Are famil-iar
3
3 where II am?
with where
with am?

44 A
A First paragraph.
First paragraph.
04:26
04:26 tr
5
J O
Q Yeah. And
Yeah. Andwe've tal-ked about
we 've talked that
about that
66 little bit.
photograph aa little
photograph bit. But what II want
But what to know
want to know

71 is: DoDoyou
is: youbelieve that these
bel-ievethat folks communicating
thesefolks communicating
8 with Ford
with Ford Credit put her
Credit put her at risk of
at risk physical harm?
of physical harm?

9 A Possibly, yes.
Possibly, yês.
04:27 I0
04:21 10 r\
Q is that?
Why is
Why that?
11
11 A of the
Because of
Because that they'd
things that
the things they'd been
12
L2 involved in, which
involved in, which are
are consistent with sovereign
consistent with sovereign
13
13 citizen type behavior.
citizen type behavior.
I4
14 O
Q And what does
And what that mean?
does that mean?

04:21 15
04:27 15 A
A That means
That that although
means that and II don't
although -- and don't
16
L6 have that Ford
evidence that
have evidence Ford knew
knew they were sovereign
theY were soverer_gn
17
L1 citizens but Monica Jones,
citi zens -- but Sheri Moody,
Jones, Sheri Moody, and
and

18
1B Brown, based
Cindy Brown,
Cindy based on
on exhibits or documents
exhibits or or
documents or
19
L9 videos or
videos or accounts from Ms.
accounts from Albert, II do
Ms. Albert, do believe
believe
04:21 20
04:27 20 t hat they
that thev are
âr ê acting
e r-1-'ì no in ce I t-.1 ì n tactics
i n certain -^!
tar:t 'i r-q that
^ 1-h¡l are
,arê

2I
21 r a
used by sovereign r
citizens. And that could result

22
22 phvsical- -- or
in physical
in or some tvoe of
some type of damage t ô Ms.
damaqe to Ms - Albert.
Al bert- -

23
23 O
Q Well, know about that.
Wel-], II know that. You've talked
You've talked
24
24 about, for
about, instance, that
for instance, her car
that her car was like her
was like her
04:28 25
04:28 as an
office, as
office, attorney, and
an attorney, that would
and that put her
woul-d put in
her in

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MEINHARDT - 07/1.0/2OIB

1
L sort of
sort criminal --
of criminal
2
2 O
Q Well, that's
WelI' a different
that's a different issue. Would you
issue. Would you
3
3 agree that
agree it's difficult
that it's difficult to
to speculate
speculate what
what an
4
4 individual will
individual will or
or will not do
will not ín the
do in the future?
future?
04:29
04:29 q
5 A
A True.
True.

6
6 O k
Okay. t
So I'm not talking about what we

7
1 think somebody may possibly do someday. I'm

8B 1n if you have any


wondering ifi
n information, specifically

9
9 Br
as to Cindy Brown, h
that she's ever
EV engaged in

04:29 t0
04:29 10 somethi cr nhvsicallv
something physically v i ol ent-?
violent?

11
11 A No-
No.

I2
12 O And same Question as to Sheri MMoody. Do

13
13 vou
You hav
have any informatio n that
anv information that she's
she's engaged in
en aoecl in

I4
14 anvthinq phvsicallv
anything physically violent?
violent?

04:29 15
04:29 15 A
A I ìrrql
T lust l-rrrza
have ha.a rd that
heard .l-l-ra{- cha
she r¡râe
was inanaa fight
f ì al-r l-

16
L6 with her bovfriend.
with her it- resulted
That it
boyfriend. That resulted in
in hosoital
aa hospital

I1 visit
17 a cl broken
visit and broken bone, T guess.
bone, I clress -

18
1B OAn And who
O who \^ias
was the ao crres sor ?
the aggressor?
19
19 A Iwwasn't there. I couldn't tell you. But
I B

04:30 20
04:30 there was a fi h
fight. And who was at fault? I don't

21
2L know.
know.

22 ô
O Ç¡r you
So Ànn f 'l- have
\z-ìt . don't l'r¡rza ãn\/
any inf
information .|-l'r ll-
¡'l- i nn that

23
23 Sheri Moodv
Sheri has aa history
Moody has hist-orv of viole ee herself?
of violence herself?

24 A T understand
I rrr.r araJ-¡nrl cl'la
she r¡rîa
was in ¡ fight.
f n a t'i nl-rJ-

04:30 25
04:30 25 O But are you aware
w that she was a victim
V of

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1
L domestic violence?
domestic violence?
2 A
A I lm nr.l
I'm not | îr¡r1rô
aware ¿^rf
of lha a llr at
the qsituation. T just
I irrcl-

3
3 know t.hat
know she was
that she in a
was in f iqht.
a fight.
4
4 O And ques 'i on wi
same question
And same th regard
with reoard to
to
04:30
04:30 5
5 Monica
Monica Jones. vouhave
Doyou
Jones. Do haveany informat ion regarding
anv information reqardinq
6 Monica Jones r s past
Monica Jones's historv with
nast- history with regard to whether
reqa cl to whet-her
7
1 ôr not
or nn1- she's
q. Âle rl h r¡q ''ì r-¡ I I r¡ dangerous?
physically .l nnarz.rrl q ?

o
8 A Ibe
I i eve there
believe t-here was an E-mail
was an from
E -mail from

9
9 n ¡) calling Ms. A1
Monica Jones rt a C-U-N-T and
Albert

04:31 10 vôlr know,


savinq, you
saying, know, that
that if she came
if she down her
came down st.reet-,
he street,

11
11 that- she'd
that l¡e beat
sherd be bea t. up that E-mail
r1T) -- that E*ma i I --

12
72 O I don't think that \^Iwas Monica Jones.
I

13
13 A T h:l
That r.7ac
was ñiCindy
nÄr¡ F,rn
Brown;
\^/n rt_ nl-rt2
right? Nln?
No?
^
I4
14 O
a) I
T don't I h i nl¿ it
rlrtn | | think i .l- r^rîa
was either f those
a'i l-ha Y of J-l.raca

04:31 115
5 people.
People.

L6
16 A
A What?
What?

I1
17 MS. ALBERT: Karen Rozier.
ALBERT: Karen Roz'i er-

18
1B THF, InITTNESS
THE WITNESS: : Oh, ren Rozier?
Oh, Karen Okav.
Rozier? Okay.

I9
19 BY THE
BY THE VüITNESS:
WITNESS:

04:31 20
04:31 O Is it fair tv looked
f l-r to say that you've I at a

2L
21 number of different individuals,
AV n I
so you're unclear

22
22 as to who
as to said what?
who said what?
23
23 A
A Vüell-, I cl have
Well, I'd have to
to review
review -- yeah. Thatrs
ah - That's

24
24 verv fair.
very fair.

04:31 25
04:31 O
O Butaass you
But voll sit
sit here,
here, you
vou don't
do I t- have anv
any

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EXPERT
EXPERT GREGORY
GREGORY MEINHARDT OI/70/2OIB
METNHARDT -- 01/10/2018

1
1 reason to
reason to believe
bel-ieve that
that Monica
Mo n'ì ea Jones has engaged
,TÕnes has in
enoacred in
2 anv physical
any ohvsical violence
viol ênce in
in her
her past?
nast.?
3 A
A II do not.
do not.
4 Q
O If don't think II have
don't think have anything further, sir.
anything further, sir.
04:31
04:31 5( Thank you for
Thank your time.
for your time.
66 A I'm you know
sorry, you
f 'm sorry, know --

77 ALBERT: VüAit.
MS. ALBERT: Wait. WAit. NO. No.
Wait. No. NO.Let
LCt me
MC

8oo get in
get in a follow-up
follow-up question.
question.
99 THE WITNESS:
THE Okay.
WITNESS: Okay.

04:31 10
04:31 10 EXAMINATION
EXAMINATION

11
11 BY MS. ALBERT:
BY MS. ALBERT:

12
T2 O
Q Hypothetically, if there
Hypothetically, if there was
was evidence of aa
evidence of
13
13 partial- audio
partial audio recording where II called
recording where call-ed Ford Credit
Ford Credit
14
L4 and II told
and told them, prior to
them, prior to the that
repossession, that
the repossession,
04:32
04:32 15 there were
there \^/ere sovereign threatening my
citizens threatening
sovereign citizens life
my life
16
L6 and II needed
and locks on
needed locks the car
on the and II needed
car and the
needed the
17
L7 registration papers, would
regi s trati on papers, t,hat, then,
would that, then, change your
change your
18
1B opinion that
opinion that would that
would be some
that be some evidence that
evidence that
19
L9 Ford Credit
Ford had knowledge
Credit had that any
knowledge that any third party that
third party that
04:32 20
04:32 might contact
might cont.act them
them could be aa sovereign
could be citi zens ?
sovereign citizens?
21
27 THE Itrs time
CLERK:It's
THE CLERK: to go.
time to go. Sorry to kick
Sorry to kick
22 out, but
you out,
you but you've got to
you've got to go.
go.
23 MS. ALBERT:Answer
MS. ALBERT: questron.
the question.
Answer the
24 WITNESS: II need
THE WITNESS:
THE need it again. I'm
it again. Irm sorry.
sorry.
04:32 25
04:32 25 door knock
The door
The threw me
knock threw off.
me off.

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EXPERT
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GREGORY MEINHARDT OI/70/2018
ME]NHARDT -- 01/10/2018

11 OF CALIFORNIA
STATE OF
STATE CALIFORNIA ))
2
2 COUNTY oF LOS
couNTY OF LOS ANGELES
ANGELES )) ss.
SS.

3
?

4TA It Barbara
I, Prokop' CSR
Barbara Prokop, No. 14190,
CSR No. in
I4I90, in
5q for the
and for
and the State
State of California, do
of California, do hereby certify:
hereby certify:
66 prior to
That prior
That to being
being examined,
examined, the witness named
the witness named

71 in the
in foregoing deposition
the foregoing deposition was by me
was by duly sworn
me duly to
sworn to
8O testify the truth,
to the
testify to the whole
trut.h, the truth, and
whole truth, nothing
and nothing
99 but the
but truth;
the truth;
10
10 That said
That deposition was
said deposition taken down
was taken by me
down by in
me in
11
11 at. the
shorthand at
shorthand time and
t.he time place therein
and place therein named
named and
and

I2
12 thereafter reduced
thereafter reduced to typewriting under
to typewriting under my
13
13 direction, and
direction, the same
and the is aa true,
same is correct, and
true, correct, and

I4
14 transcript of
complete transcript
complete said proceedings;
of said proceedings;
15
15 if the
That if
That the foregoing pertains to
foregoing pertains original
the original
to the
16
L6 of aa deposition
transcript of
transcript deposition in federal case,
in aa federal case, before
before
17
T1 of the
completion of
completion proceedings, review
the proceedings, of the
review of the
18
1B transcript was
transcript required;
\^Ias required;
L9
19 further certify
II further that II am
certify that not interested
am not in
interested in
20
20 the event
the event of the action;
of the act.ion;
2L
21 Witness my
Witness hand this
my hand 17th day
this 17th of January,
day of January, 2018.
2018.
22
22

23
23 óúxfunn fnoq'
24
24 Certified Shorthand
Certified Reporter
Shorthand Reporter
25
25 for the
for the State of California
State of California

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